Memorandum Opinion
LEMIRE, Judge:
This proceeding involves a deficiency in petitioners' income tax for 1951 in the amount of $12,639.48 and additions to the tax under section 293(a), Internal Revenue Code of 1939, in the amount of $631.97.
The sole contested issue is whether for the taxable year 1951 petitioners are entitled to accrue a contingent liability resulting from their breach of certain...
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