DAVID A. NELSON, Circuit Judge.
This is a tax case that arose out of a somewhat unusual set of facts. In its federal income tax return for 1974 the taxpayer reported — and paid taxes on — an income item of more than $100,000 that was accrued on the taxpayer's books in that year but was not actually received. The government has stipulated that this item was "properly reported" as income in 1974. In 1975 it became clear, according to the taxpayer, that...
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