The respondent determined a deficiency in petitioner's excess profits tax for the calendar year 1945 in the amount of $3,666.53. Petitioner claims an overpayment of $13,318.37. The only question before us is whether a credit or refunds of New York State franchise taxes, which resulted from renegotiation of part of petitioner's 1943 and 1944 income by the Federal renegotiating officials, should be included in its income for the year 1944 or 1945.
FINDINGS OF FACT...
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