Memorandum Opinion
FAY, Judge.
Respondent determined a deficiency of $1,738,691 in petitioner's Federal income tax for the year ended December 31, 1984. After concessions by the parties, the only remaining issue for decision is whether, under the accrual method of accounting, State income and replacement tax refunds attributable to net operating loss (NOL) carrybacks should be included in petitioner's gross income in either: (1) The year of the loss which...
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