Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a $45,250.58 deficiency in petitioner's income tax for its taxable year ending August 31, 1971.
Other issues having been conceded by the parties, the sole issue remaining before us is whether there was a satisfaction or disposition of petitioner's installment sales obligation, thereby triggering immediate recognition of gain under section 453(d).
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