OPINION.
HILL, Judge:
This proceeding involves income tax deficiencies for the calendar years 1939 and 1940 in the amounts of $272.66 and $3,442.70, respectively. Respondent determined that petitioner was taxable as a nonresident foreign corporation. Petitioner assigns this action as error. This is the only issue before us. Petitioner filed its income tax returns for the years in question with the collector of internal revenue for the third district...
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