OPINION.
RAUM, Judge:
The Commissioner determined a deficiency in income tax in the amount of $379,848.55 for the calendar year 1952. The parties have filed a comprehensive stipulation of facts, and although some testimony was received, it does not appear to be necessary to make any findings beyond the stipulation which we hereby adopt as our findings of fact.
Petitioner, an accrual basis taxpayer, sold its products on installments, and arranged...
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