Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the year 1947 in the amount of $155,567.68 and a penalty of $10,869.22 for substantial underestimation of tax. The issue is whether respondent was correct in determining petitioner's gross income from his lumber business on an accrual basis and including $183,557.15 therein as accounts receivable without taking into consideration that part outstanding...
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