This proceeding involves deficiencies in income and excess profits tax for the calendar years 1950 and 1951 in the respective amounts of $358,446.35 and $300,641.42. The issues for decision are:
1. Whether petitioner, in determining its equity capital within the meaning of section 437 of the Internal Revenue Code of 1939, is entitled to accrue as assets as of the beginnings of the taxable years 1950 and 1951, respectively, the amounts of overassessments plus interest...
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