Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves income taxes for the calendar years 1938 and 1939. Deficiencies were determined by the Commissioner in the amount of $2,443.44 for the calendar year 1938 and in the amount of $2,800 for the calendar year 1939.
Part of the deficiency for each year, 1938 and 1939, is due to the disallowance by the Commissioner of an amount claimed by the petitioner as credit against its...
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