OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $64,047.43 in excess profits tax for the calendar year 1944. It arose from the disallowance of an unused excess profits credit carry-back from 1946.
All of the facts have been stipulated.
The petitioner, which was organized on May 13, 1931, and is a Texas corporation, filed its tax returns for the years 1944, 1945, and 1946 with the collector of internal revenue for...
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