OPINION
NIMS, Chief Judge:
Respondent determined a deficiency in petitioner's 1981 Federal income tax in the amount of $385,708. The issues for decision are: (1) Whether petitioner properly apportioned and allocated the discount incurred on its transfer of accounts receivable to its domestic international sales corporation (DISC) in computing the commission payable to the DISC under full cost accounting; (2) whether petitioner properly applied the...
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