S. EVERETT, J.
Petitioner has appealed from the order of the Tax Tribunal affirming the determination and redetermination by respondent that there was a deficiency in petitioner's franchise fee liability for the years 1975 and 1976. The sole issue presented is what is the proper method for determining a reserve for losses through loans made in the course of petitioner's business. Such a reserve may be subtracted from the surplus in determining the proper franchise...
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