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          adjustment were not treated as making the tax adjustment                    
          contested and nonaccruable.                                                 
               H.E. Fletcher Co. v. Commissioner, a Memorandum Opinion of             
          this Court dated Oct. 26, 1951, involved a taxpayer’s attempt to            
          accrue interest relating to tax adjustments in the year in which            
          the interest was paid, not for years to which the interest                  
          related.  The case involved no evidence that the tax adjustments            
          were contested or other than fixed and definite.  The Court did             
          not allow the accrual basis taxpayer to accrue the interest in              
          the later year in which the interest was paid.                              
               As we understand the above authorities, situations which               
          would allow the accrual of interest relating to tax audit                   
          adjustments for the years to which the interest relates generally           
          are distinguishable from situations such as those involved herein           
          (namely, situations where facts relating to the tax audit                   
          adjustments and the amounts thereof are, for a number of years,             
          indefinite, where the adjustments are eventually developed based            
          largely on information available to both taxpayers’ and                     
          respondent’s representatives only over the course of years after            
          the filing of the tax returns, where negotiations occur with                
          regard to the nature and character of the underlying transactions           
          giving rise to the tax adjustments, and where agreements with               
          regard to the tax adjustments are reached through such                      
          negotiations years after the filing of the tax returns to which             
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