Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies against petitioner for 1983 and 1984 in the amounts of $125,069.46 and $99.20, respectively. The primary issue presented is whether "bottle deposits" taken by petitioner in accordance with Massachusetts law are required to be included in income in the year of their receipt by petitioner. If we find that the deposits must be included in petitioner's income...
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