The Commissioner determined deficiencies of $97.71 and $184.03 in declared value excess profits tax and $3,622.15 and $15,065.52 in excess profits tax for 1941 and 1942, respectively.
The issues are whether the petitioner was entitled to exemption from excess profits tax as a personal service corporation during both years, and, if so entitled, whether it signified its desire to be exempt for 1941, under section 725 of the Internal Revenue Code, as amended.
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