These consolidated proceedings involve excess profits tax deficiencies for the calendar years 1940 and 1941, in the respective amounts of $3,411.19 and $1,384.90. The sole issue is whether petitioner, an installment basis taxpayer, having elected under section 736 (a) of the Internal Revenue Code to report its income for excess profits tax purposes on a straight accrual basis, is entitled to bad debt deductions on account of installment sales made prior to January 1, 1940...
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