PER CURIAM.
We have duly considered the record, the briefs and oral arguments in this case, which comes before us on petition by the utility taxpayer for a review of the decision of the Tax Court of the United States finding a large deficiency in income taxes for the year 1951, the sole question for determination being whether a rate differential refund of more than a million dollars accrued and was deductible by the petitioner for federal income tax purposes in 1950...
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