MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Frank's Casing Crew and Rental Tools, Inc., petitioned the Court to redetermine respondent's determination of income tax deficiencies of $182,660, $164,150, and $46,461 in its taxable years ended August 31, 1989, 1990, and 1991, respectively. Following concessions by respondent, we must decide whether respondent committed an abuse of discretion in changing petitioner's method of accounting for income from...
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