Respondent determined a deficiency in petitioner's income and excess profits tax for 1953 in the amount of $3,280,059.67. Petitioner claims an overpayment in the amount of $5,254,252.35. The only issues remaining for our determination are (1) whether petitioner properly treated profit derived from sales of some of its equipment as being taxable as capital gain rather than ordinary income; (2) whether petitioner, an accrual basis taxpayer, is entitled to deduct property taxes...
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