Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in petitioner's 1986 and 1987 consolidated Federal income tax in the amounts of $60,558 and $30,508, respectively. The issues presented for our consideration are: (1) Whether franchise fees are includable in the year of receipt or in the year the contractual performance is complete; and (2) whether gasoline pump canopies, fixtures, and signs should be classified in...
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