GODDARD, District Judge.
Cross-motions for summary judgment. The facts were stipulated.
Plaintiff corporation overpaid its income and declared value excess profits taxes for 1943 and 1944 in the sum of $174,298.72. By a Revenue Agent's report, dated March 15, 1951, sent to the taxpayer under date of April 20, 1951, the Internal Revenue Agent-in-charge proposed an overassessment of $174,298.72 for the years 1943 and 1944, and a deficiency in tax of $68,685...
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