OPINION.
MULRONEY, Judge:
Respondent determined a deficiency in the income and excess profits tax of petitioner for the year 1950 in the sum of $3,618.14. Petitioner does not contest respondent's adjustments which resulted in the deficiency but petitioner claims an overpayment of income tax for said year in the sum of $5,348.06.
The only question for decision is whether amounts, received in 1950 for services rendered in 1949, are includible...
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