Memorandum Opinion
OPPER, Judge:
Respondent determined a deficiency of $1,653.34 in petitioner's income tax for the taxable year October 1, 1954 to March 31, 1955.
The sole issue is whether amounts which a financial institution, discounting petitioner's paper, credited during the year in issue on its books to the reserve account of petitioner, an automobile dealer on an accrual basis of accounting, are taxable in that year.
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