Memorandum Opinion
OPPER, Judge:
Respondent determined a deficiency of $14,041.30 in petitioner's 1945 income tax, not all of which is in controversy. The sole issue is whether expenditures in excess of O. P. A. ceiling prices are includible as costs of goods sold in computing petitioner's gross income.
All of the facts are stipulated and are hereby found accordingly. The stipulation is substantially as follows:
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