OPINION.
TURNER, Judge:
The respondent determined deficiencies in excess profits tax of $34,333.63, $78,922.56, $73,466.43, and $24,614.14 against petitioner for its taxable years ended December 31, 1941, 1942, 1943, and 1944.
The only question now submitted is whether in this proceeding the Court has jurisdiction to consider the applicability of section 721 of the Internal Revenue Code.
Petitioner is a Pennsylvania corporation, with...
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