PER CURIAM.
This appeal concerns the federal income tax treatment of beverage can deposits (5 cents per can) collected by a beverage wholesaler pursuant to the Massachusetts bottle deposit law, Mass.Gen.Laws ch. 94, §§ 321-327 (1986). First, the taxpayer argues that these deposits need not be considered income, but instead can be treated as liabilities in an accounting reserve. Second, the taxpayer argues that if the deposits are deemed to be income...
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