Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the calendar years 1973 and 1974 in the respective amounts of $200,062.11 and $274.22. After various concessions made by the parties prior to trial, as well as upon brief, only one issue remains for the Court to decide: whether, under the facts of this case, an installment sale of certain securities...
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