The respondent determined a deficiency in petitioner's income tax for the year 1949 in the amount of $11,724.50.
The sole issue is whether a $30,000 advance payment received in 1949 by the petitioner lessor, an accrual basis taxpayer, pursuant to lease contract is includible in gross income in 1949, as determined by the respondent, or in 1959, the year in which the advance payment is to be applied as rent.
FINDINGS OF FACT.
Some of the facts were...
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