DAWSON, Judge:
Respondent determined a deficiency in income tax against the petitioner for the taxable year 1956 in the amount of $8,542.74.
The issues presented for decision are:
(1) Whether the petitioner's right to receive a refund from the General Motors Advertising and Promotional Funds became fixed and the amount thereof ascertainable with reasonable accuracy during 1956 so as to require it to be accrued as income in that year.
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