Memorandum Opinion
OPPER, Judge:
This proceeding brings into controversy a deficiency determined against petitioner in income tax for the year 1939 in the amount of $297,266.48. Petitioner, a Pennsylvania corporation, filed its Federal income and excess profits tax return for the calendar year 1939 with the collector of internal revenue for the twenty-third district of Pennsylvania.
All of the facts are stipulated and are hereby found accordingly...
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