OPINION.
LEECH, Judge:
The petitioner is a Delaware corporation, and has its principal office in Pittsburgh, Pennsylvania. Its return for the year 1938 was filed with the collector of internal revenue in that city. The respondent has determined against it a deficiency in income tax for the year 1938 in the amount of $15,112.55. The petitioner claims an overpayment of $19,500.
All of the facts have been stipulated and are found as stipulated...
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