TIETJENS, Judge:
The respondent determined a deficiency in income and excess profits tax of $76,652.78 for the fiscal year ended June 30, 1952, and a 5 per cent addition to the tax for late filing, amounting to $3,832.64. The principal issue is whether an amount credited to the petitioner in the taxable year is includible in gross income for that year or was accruable in earlier years. By amendment to the petition there is raised the alternative contention...
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