OPINION.
OPPER, Judge:
This proceeding grows out of a partial denial of an application for relief from excess profits tax under section 722. Respondent's rejections of the claims for refund were in the respective amounts of $7,744.05 for 1942 and $5,796.24 for 1945. As to the latter year, respondent has now abandoned his contest, so that the only year remaining in controversy is 1942 and the only question to be decided
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