Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $163,401.10 in the income tax of the petitioners for 1954. The Commissioner in determining the deficiency added $225,205.08 to the income as disclosed by the return and explained:
(a) In your return for the taxable year 1954 you reported your income and deductions on the accrual basis, which was a change from the cash basis of reporting used in the years 1942 to and including...
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