This proceeding involves a deficiency in excess profits tax for the taxable year ended September 30, 1945, in the amount of $105,995.01. Petitioner claims an overpayment in excess profits tax in the amount of $5,276.43 for such taxable year.
The issues presented are (1) whether the loss occurring in the taxable year 1946 from the worthlessness of stock of petitioner's subsidiary corporation is an ordinary loss, under section 23 (g) (4) of the Internal Revenue Code...
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