Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent, using the accrual method of accounting, made the following determinations with respect to petitioner's income tax:
Year Deficiency Overassessment 1963 .................. $9,383.92 ........ 1964 .................. ........ $1,099.53 1965 .................. 876.28 ........
Since petitioner has not placed in issue...
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