MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $306,731 and $80,346 for the taxable years ending May 31, 1995, and May 31, 1996, respectively. The sole issue for decision is whether amounts which petitioner received from its customers in excess of the amounts petitioner was owed (customer overpayments) constitute gross income in the year of receipt.
Unless otherwise...
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