OPINION
WRIGHT, Judge:
Respondent determined a deficiency in petitioner's 1987 Federal income tax in the amount of $111,155.63. The deficiency is based on a $300,700 adjustment to income. Petitioner did not contest $700 of the adjustment related to an increase in rental income. As such, only the $300,000 adjustment remains in dispute.
The sole issue for consideration for taxable year 1987 is whether under section 461(f)
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