Respondent determined deficiencies in petitioners' income taxes of $2,283.22 for the year 1948. Some of the adjustments are uncontested; others are conceded or have been settled by stipulation of the parties. The remaining questions are (1) whether certain amounts received in the year 1948 may properly be allocated over prior years under section 107 (a) of the Internal Revenue Code of 1939; and (2) if these amounts may be so allocated, whether they may be further allocated...
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