OPINION.
BLACK, Judge:
The Commissioner determined deficiencies in income tax for the taxable (calendar) years ended December 31, 1950 and 1951, in the amounts of $10,705.38 and $3,181.84, respectively.
The deficiency for the year 1950 is due to the respondent's determination that property taxes imposed for the year 1951, which were levied on December 20, 1950, but which became a lien on the property on January 1, 1951, accrued and became...
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