Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined deficiencies in income tax for the taxable years ending December 31, 1949, and 1950 in the amounts of $1,927.68 and $1,718.02, respectively.
The issues are: (1) Whether petitioner can properly defer to a subsequent year income from television service contracts where such income was received without restrictions on its use during the taxable year, and (2) whether petitioner...
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