MEMORANDUM OPINION
WRIGHT, Judge:
Respondent determined an overassessment of $137,840 and a deficiency of $2,330,954 in petitioner's Federal income taxes for 1965 and 1966, respectively. After concessions by the parties, two issues remain for decision: (1) whether petitioner is entitled to a deduction of $4,359,000 on its 1966 return to reflect a loss from a long-term contract, income from which was reported in the taxable years...
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