OPINION
STERRETT, Judge:
Respondent determined deficiencies in petitioner's corporate Federal income taxes for the calendar years 1962 and 1963 in the amounts of $1,213,379.04 and $34,800.89, respectively. The sole issue for decision is whether petitioner, an accrual basis taxpayer, may deduct, pursuant to section 162, I.R.C. 1954, the unpaid portion of its obligation at the end of 1962 and 1963 to make contributions to employees' trusts established...
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