Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for 1988 and 1989 of $166,347.19 and $173,821.63 respectively.
The issues for decision are: (1) Whether all amounts collected by petitioner from customers for long-term vehicle service contracts (hereinafter VSC) must be included in gross income in the year of receipt under section 61.
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