Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies of $2,406.70 and $49,609.16 in petitioner's Federal income taxes for its fiscal years ending September 30, 1968, and September 30, 1969, respectively. The only issue remaining for decision is whether the estimated costs of repairing and replacing defective parts furnished by petitioner under a subcontract accrued under section 461(a)
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