OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes for the taxable years 1962, 1963, and 1964, in the amounts of $58,103.84, $8,381.01, and $8,587.10, respectively. The issue for decision is whether petitioner is entitled to deduct from its underwriting income in the year 1965 the total unearned-premium reserve accumulated on its books during the years 1959 through 1964 and carry back to the years 1962 through 1964...
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