THORNBERRY, Circuit Judge:
This appeal from the district court's judgment in favor of the Internal Revenue Service raises the question whether appellant, a personal holding company during the years at issue, is entitled to a § 545(b)(1) deduction for the tax years 1968-70, even though appellant did not pay the income taxes giving rise to the deduction until 1971 and contested the payment in 1973. The district court held that the year of payment governed the timing...
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