MEMORANDUM OPINION
LARO, Judge:
The parties submitted this case to the Court without trial. See Rule 122. Petitioner petitioned the Court on January 26, 1998, to redetermine respondent's determination of deficiencies in petitioner's Federal income tax for fiscal years ended April 30, 1990 and 1991. Respondent determined petitioner must compute its income and expense on the cash receipts and disbursements method (cash method) rather than an accrual method...
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