Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent has determined a deficiency in income and excess profits tax of petitioner for the year 1953 in the amount of $78,851.43. The issues presented are: (1) whether, under the accrual method of accounting, dividends on group insurance policies received by petitioner in 1954 are properly accruable in 1953; (2) whether a failure by petitioner to accrue such dividends in 1953 constitutes a change...
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