Respondent determined deficiencies in income tax for the taxable years ending April 30, 1950, 1951, and 1952, in the respective amounts of $197,306.17, $553,786.68, and $270,905.32.
The only issue is whether a purported sale and leaseback of certain land in Lower Manhattan was in fact a sale for tax purposes resulting in a deductible loss or whether it constituted an exchange of property for property of like kind (plus cash) with the result that no loss is deductible...
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