OPINION.
OPPER, Judge.
Deficiencies of $736 and $4,713.26 in declared value excess profits tax and excess profits tax, respectively, for the taxable year ending May 31, 1944, are involved. The single issue is whether the New York State franchise tax, payable partly in September 1944, and partly thereafter, is deductible by an accrual basis taxpayer for its fiscal year ending prior thereto. All of the facts were stipulated and are hereby so found....
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