FISHER, Judge:
This proceeding is for the redetermination of a deficiency in petitioner's income tax for 1954 in the amount of $183,503.13. The deficiency results from respondent's disallowance of a portion of a net operating loss carryback from the year 1956. Most of the facts have been stipulated. The basic issue is whether or not the sum of $500,000 (out of a total of $600,000 of minimum royalties) was accruable in 1956.
FINDINGS OF FACT
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