MEMORANDUM OPINION
NIMS, Judge:
Respondent determined Federal income tax deficiencies for petitioner's tax years ended April 1996 and April 1997, in the amounts of $54,645 and $71,260, respectively. After concessions, the sole issue for decision is whether deductions taken by petitioner, for depreciation of gas station properties, represent a change in accounting method made without securing the "consent of the Secretary" as required under section 446(e...
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