OPINION.
LeMIRE, Judge:
This proceeding involves a deficiency of $122,692.62 in excess profits tax for 1941. The petitioner concedes liability for $604.05 of that amount. The contested portion of the deficiency results from the respondent's disallowance of an excess profits credit carry-over for 1940.
The parties have filed a written stipulation of facts reading, in material part, as follows:
1. The Petitioner is a Minnesota corporation...
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