SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioner's Federal income taxes: $134,073 for 1974, $553,254 for 1975, $174,668 for 1976, and $18,446 for 1977. After concessions by the parties, the only issue for decision is whether, in the circumstances of this case, customer deposits received by a public utility are includable in income upon receipt as advance payments.
FINDINGS OF FACT
To the credit of both...
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