DRENNEN, Judge:
Respondent determined a deficiency of $834,778 in petitioner's 1976 Federal income tax. Due to concessions, the only issue is whether a "loan origination fee" charged by petitioner in connection with loans it made constituted interest, a charge for services, or, in part, both.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The stipulation of facts and exhibits attached thereto are incorporated...
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