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method authorized by the Code and consistently applied,
petitioner does not argue that a method contrary to law is
nonetheless acceptable so long as it has been consistently
applied.
We therefore hold that petitioner is not entitled to
currently deduct license and insurance expenses allocable to the
following taxable year. Respondent’s determination of a
deficiency with respect to petitioner’s 1993 taxable year is
sustained.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011