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Year Amount
1990 $1,440,821
1989 923,274
1988 488,357
1987 179,881
1986 43,181
1985 8,470
1984 195
3,084,179
Petitioner's trial memorandum makes the following statement
concerning this element of respondent's adjustment:
Respondent's schedule indicates it totals
$3,084,179, but it actually foots to $3,079,767.
Aside from this small difference, petitioner
agrees that if a change in accounting method is
required here, this is the correct method to use
and that it arrives at the correct starting point
to compute 1990 income.
Petitioner did not specifically take issue with this
element of respondent's adjustment, either at trial or
in its post-trial briefs.
The second element of respondent's adjustment is based
upon the discrepancy in petitioner's deferred interest
account. On the one hand, the balance sheet submitted
with petitioner's 1990 return as Schedule L reports
$7,772,543 as the balance of petitioner's deferred interest
account at the end of 1990. On the other hand, the
aggregate deferred interest recorded on the ledger cards
for all of the loans outstanding at the end of 1990 is
$6,175,575. Thus, petitioner's balance sheet reports
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