Memorandum Opinion
HARRON, Judge:
The respondent determined an income tax deficiency of $1,929.89 for 1957.
Petitioners filed their return with the district director of internal revenue for the lower Manhattan District, New York City. Joseph Tolins is referred to herein as the petitioner.
In 1955, petitioner sold a 30 percent interest in improved real estate. Part of the purchase price was paid by notes secured by third mortgages. In his...
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