The Commissioner disallowed petitioner's application for relief under section 722 of the Internal Revenue Code and its claim for refund for excess profits tax in the amount of $1,311.75 for the year 1940 for the reason that petitioner has not established (1) that the tax computed under subchapter E of chapter 2 of the Internal Revenue Code without the benefit of section 722 resulted in an excessive and discriminatory tax within the provisions of section 722 (a) and (b) (5...
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