RICE, Judge:
The respondent determined deficiencies in excess profits tax for the taxable years 1944 and 1945 in the amounts of $60,498.21 and $47,314.33, respectively, and a deficiency in income tax for the taxable year 1946 in the amount of $4,969.81. Petitioner claims relief from excess profits tax liability for the years 1944 and 1945 under section 721 of the Internal Revenue Code, which relief respondent has denied.
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