O'BRIEN, District Judge.
The facts in this case have been stipulated. There are two questions presented to the Court. First, whether or not certain state inheritance taxes paid in 1920 and 1921, which the taxpayer under a compromise agreement executed in 1920 agreed to repay, are deductible as an accrued item for the taxable year 1919; and second, whether if such item is accruable in 1919 as contended by the taxpayer, he must also accrue income from the share of royalties...
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