SWYGERT, Chief Judge.
The material facts in this case have been stipulated. The government states in its brief that the initial question for decision is: "Did the tax return apprise the Commissioner that the plaintiff's return should have been filed on the accrual basis so that income for tax purposes should be reported on the accrual basis?" The plaintiff concedes that this is substantially the question to be decided, but in its brief the plaintiff rephrases the...
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