FRANK, Circuit Judge.
The question presented is whether a condemnation award to a mortgagee on a non-assumed mortgage is taxable as a gain to the owner of the properties under the provisions of § 112(f) of the Internal Revenue Code, 26 U.S.C.A. § 112(f). The Tax Court found that the taxpayer's "property was condemned and involuntarily converted into money in the amount of $44,096.67," and accordingly held that no gain to the taxpayer was to
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