OPINION
MULRONEY, Judge:
The respondent determined a deficiency in income tax of the estate of John A. Biewer, for the taxable period June 26, 1956, through December 31, 1956, in the amount of $31,512.27.
The deficiency results from respondent's changing petitioner's accounting method from the cash receipts and disbursement method to the accrual method and requiring petitioner to include in income, sums collected during the period in issue...
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