Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax for the taxable years 1948 and 1949 in the amounts of $169,157.12 and $128,221.42, respectively. The first question is whether monthly payments, which were made under agreements with dealers covering 93 pieces of heavy construction equipment which petitioner used in its business and to which petitioner eventually took title, in the total amounts of $731,046 during 1948...
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