Accordingly, petitioner, to prevail here, would additionally have to show that it is entitled to a constructive average base period net income large enough to result in credits exceeding those available under the invested capital method. Cf. N. Hess' Sons, Inc., supra, at 402; and Hall Lithographing Co., 26 T.C. 1141, 1156, quoting Mokry & Tesmer Machine Co., 23 T.C. 12, 18. From all of the above, we hold that