OPINION
RAUM, Judge:
The Commissioner determined a deficiency in petitioner's 1972 Federal income tax in the amount of $78,750 and an addition to tax under section 6651(a), I.R.C. 1954, in the amount of $3,938. Petitioner is a former member of an affiliated group of corporations that filed consolidated returns. After concessions, the only issue presented is whether petitioner, an accrual basis taxpayer, may deduct in the year at issue any part of...
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