Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency in the amount of $277,987 in petitioner's income tax for the taxable year ending March 31, 1974. The issues presented are:
(1) whether petitioner realized capital gain or ordinary income from the sales of three tracts of real estate;
(2) whether a $66,000 loan acquisition fee for construction financing is deductible in full in the year paid or is...
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