PIERCE, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1949 in the amount of $4,028.89; and a deficiency in its income and excess profits tax for the year 1950 in the amount of $28,915.69. The petitioner, in its petition to this Court, challenged these deficiencies and alleged that said taxes were overpaid in the amounts of $7,305.70 and $305,904.51, respectively. Thereafter the respondent, in an amended answer to the petition...
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