Appeal of Uvalde Co.

*935OPINION.

Littleton :

This appeal presents a similar question to that decided by this Board in the Appeal of Consolidated Asphalt Company, 1 B. T. A. 79. It is contended, however, by the taxpayer that the facts in this appeal are different from those which obtained in the Consolidated Asphalt Company's Appeal and are such as to entitle it to report its income upon a long-term contract basis as provided for in article 36, Regulations 45. Granting, without deciding, that article 36 is authorized by law, the contracts from which taxpayer received its entire income were not long-term contracts…