The Commissioner denied the petitioner's applications for relief under section 722 of the Internal Revenue Code relating to the years 1941 and 1942. It is incumbent upon the taxpayer to establish that its excess profits taxes for 1941 and 1942 (without the benefit of section 722) are excessive and discriminatory and what would be a fair and just amount representing the normal earnings to be used as a constructive average base period net income. It argues that its average...
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