NIMS, Judge:
Respondent determined a $651,156 deficiency in petitioner's income tax for the tax year 1972. Petitioner claims an overpayment of 1972 income tax in the amount of $4,032.
Due to concessions by the petitioner, the only issue remaining for decision is whether petitioner's use of the practical capacity concept in costing its goods for 1975 conformed with the requirements of section 1.471-11(d)(4), Income Tax Regs. Resolution of this issue...
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