Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined a deficiency in income tax of $14,481.13 and an addition to tax of $2,001.60, for substantial underestimate of estimated tax, against the petitioners for the taxable year 1954. The question is whether $22,469.30 of accounts receivable accrued as of January 1, 1954, was properly omitted by petitioners from 1954 income by reason...
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