Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in petitioner's Federal income taxes for the taxable year 1976 of $398,682. The issues for decision are (1) whether petitioner realized income under the tax benefit rule or claim of right doctrine in 1976 when Reading Company agreed to make payments to local taxing authorities in satisfaction of petitioner's previously deducted unpaid real estate taxes and interest, ...
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