Memorandum Opinion
FAY, Judge:
Respondent determined deficiencies of $5,604 and $16,195 in petitioner's Federal income tax for its taxable years ending October 31, 1977, and October 31, 1978, respectively. The only issue is whether petitioner, an accrual basis taxpayer, is allowed a deduction for a reserve for estimated future liability under warranty contracts furnished to customers of its rustproofing business.
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