OPINION.
OPPER, Judge:
A deficiency in excess profits tax for petitioner's taxable year ended July 31, 1945, determined in the amount of $3,179.92, is in controversy. Petitioner also claims an overpayment. One of the issues has been settled by agreement of the parties, and the question for decision is whether petitioner is entitled to deduct New York State franchise taxes accrued by it in fiscal 1945, where, due to renegotiation of its war contracts...
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