Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner in this proceeding challenges respondent's determination of income and excess-profits tax deficiencies in the amounts of $71,828.41 and $34,049.38, respectively, for the fiscal year July 1, 1937, to June 30, 1938. The question involved is whether petitioner may deduct as incurred or accrued expenses the sum of $327,500.00 for work or services to be performed subsequent to the tax year in issue...
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