The Commissioner has determined a deficiency in petitioner's income tax of $719.33 for its fiscal year ended January 31, 1948. To this determination of the Commissioner, petitioner assigns error as follows:
1. The inclusion in income of prepaid rental income in the sum of $3,138.62 as rental income in the fiscal year ended January 31, 1948;
2. Or, in the alternative, if the said amount in question, $3,138.62, does constitute taxable income to the taxpayer...
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