LARO, Judge:
This case is before the Court fully stipulated. See Rule 122. Respondent determined a $131,077 deficiency in petitioner's Federal income tax for its taxable year ended June 30, 1994. We decide primarily whether petitioner is subject to the uniform capitalization (UNICAP) rules of section 263A. We hold it is. We also decide whether the subject year is the "year of change" for purposes of...
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