MEMORANDUM FINDINGS OF FACT AND OPINION
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's 1982 and 1983 Federal income taxes in the amounts of $3,684,885 and $147,646, respectively. After concessions by the parties, we must determine whether warrants issued by petitioner to customers, in 1981, entitle petitioner to a reduction in gross income, or a deduction under section 162,
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