OPINION.
LEECH, Judge.
The Commissioner determined a deficiency in income tax of $37,989.97 for the year 1936. By an amendment to his answer he now seeks to have the deficiency increased to $42,355.41, due to the disallowance of an allegedly erroneous deduction for Wisconsin privilege dividend tax.
The issues are (1) whether the petitioner, on an accrual basis, is taxable in 1936 on dividends declared in 1936 and payable in 1937 to stockholders...
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