Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $115,437.78 in petitioner's Federal income tax for the fiscal year ended September 30, 1963. This deficiency occurred as a result of respondent's disallowance of a tentative loss caryback from the fiscal year ended September 30, 1966. We are to decide whether certain income received by petitioner from a long-term contract is reportable in the year ended September 30...
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