The Commissioner determined deficiencies in petitioner's income tax in the amounts of $156,329.93 and $166,906.57 for the fiscal years ending May 31, 1958 and 1961, respectively. The parties have agreed upon all items in dispute except one, namely, whether petitioner, a cash basis taxpayer, is chargeable, during its fiscal year ended May 31, 1961, with having realized $300,000 income, the right to which it had distributed to its shareholders during that year prior to collection...
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