Memorandum Opinion
TIETJENS, Judge:
The respondent determined deficiencies of $50 in income tax, $80,805.90 in declared value excess profits tax, and $2,020,967.49 in excess profits tax for the fiscal year ended January 31, 1945. The sole issue is whether the petitioner is entitled to deduct losses and expenses incurred in a transaction by which it sold real property used as the site of its department store and simultaneously leased such property for a term...
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