The Commissioner determined a deficiency of $617.72 in income tax for 1940 and deficiencies in excess profits tax of $17,179.65 for 1940 and $62,345.23 for 1941. The only issue for decision is whether the petitioner had net abnormal income for the taxable years resulting from development of patents or processes for steel rings, within the meaning of section 721 (a) (2) (C), which net abnormal income is attributable to prior years.
FINDINGS OF FACT.
The petitioner...
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