Memorandum Opinion
OPPER, Judge:
Respondent determined a deficiency of $5,292.78 in petitioner's income tax for the year 1954.
The sole issue is whether amounts which financial institutions, discounting petitioner's paper, credited during the year in issue on their books to the reserve accounts of petitioner, an automobile dealer on an accrual basis of accounting, are taxable in that year.
All of the facts are stipulated and are found accordingly...
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