Memorandum Findings of Fact and Opinion
Respondent determined deficiencies against petitioner in income tax and additions to tax under section 6651(a) of the Internal Revenue Code of 1954 for the years and in amounts as follows:
Year Deficiency Addition to tax 1957 .... $4,578.74 $228.94 1958 .... 834.69 41.73
The issues presented for our decision are: (1) Whether the petitioner, an accrual basis taxpayer...
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