Memorandum Opinion
GERBER, Judge:
Respondent determined a deficiency of $38,290 in Federal income tax for petitioner's taxable year ended August 31, 1978. The issue for decision is whether an accrual basis taxpayer must include, in the year of receipt, the face amount or the fair market value of a note it received from the sale of real property.
Petitioner and respondent submitted this matter fully stipulated. The stipulated facts and accompanying...
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