Respondent determined a deficiency in income tax of $93,079.09 for the calendar year 1945. Certain adjustments made in the notice of deficiency are not in dispute and only a portion of this deficiency is in controversy. The issue presented is whether the respondent erred in including in 1945 income of the petitioner, who is on the accrual basis, $181,075.02, which was received by petitioner in 1946 and reported as taxable income in that year. The income involved represents...
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