These proceedings were consolidated for trial. The issues presented are (1) whether the petitioner's applications for relief from excess profits taxes for the years 1940, 1941, and 1942 were properly denied, and (2) whether, and to what extent, overpayments claimed for the years 1940, 1941, and 1942, under section 711 (b) (1) (J), are barred by the limitations of section 322 of the Code.
FINDINGS OF FACT.
The stipulated facts are found accordingly.
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