RUWE, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years ending March 31 and December 31, 1988, in the amounts of $16,136,176 and $12,146,497, respectively.
After concessions, the issues remaining for decision are: (1) Whether petitioner must accrue brokerage commission income on the date a trade is executed or on the settlement date; and (2) whether petitioner is entitled to a deduction for its California...
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