Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioner's 1983 Federal income tax in the amount of $94,702. The issues this Court must decide are (1) whether petitioner must include in income in the year of receipt deposits and handling charges received in accordance with state law on nonrefillable beverage containers; and, if so, (2) whether petitioner...
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