Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in petitioner's income tax of $29,858.70 for 1971 and $1,941.35 for 1972. Due to concessions by petitioner, the sole issue for decision is whether respondent abused his discretion in determining that petitioner's write down of "excess" inventory of coal stoker parts did not conform to the regulations promulgated pursuant to section 471.
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