This proceeding involves unjust enrichment tax deficiencies for the taxable years ended November 30, 1935 and 1936, in the respective amounts of $4,126.58 and $795.31, plus 25 percent additional tax for failure to file timely returns. Respondent held the taxes to be due under the provisions of section 501 (a) (2) of the Revenue Act of 1936 upon the determination that petitioner had received reimbursement representing cotton processing tax in the amount of $5,158.22 in 1935...
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