OPINION.
MURDOCK, Judge:
The Commissioner disallowed the petitioner's applications for relief, under section 722 of the Internal Revenue Code, from excess profits taxes for the years 1941 and 1942. The only error assigned in the petition is the Commissioner's action in disallowing the applications. The matter under consideration at the moment is the respondent's motion to dismiss the procceeding. The motion raises the question of the adequacy of the...
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