TRAIN, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1952 and 1953 in the amounts of $362,847.34 and $424,893.38, respectively, and overassessments for the calendar years 1951 and 1954 in the amounts of $9,809.81 and $369,568.46, respectively.
The issues for decision are as follows:
(1) Whether petitioner was required to accrue amounts which it had no fixed or unconditional right to;
(2)...
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