OPINION
NIMS, Judge:
Respondent determined deficiencies in petitioner's income tax for the tax year ending June 30, 1975, in the amount of $112,515.67. Petitioner claims an overpayment of income tax in the amount of $85,166.80 for such year.
Due to concessions by the petitioner, the only issue remaining for decision is whether petitioner, an accrual basis taxpayer, may deduct the reasonably estimated expenses necessary to satisfy its obligation...
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