NIES, Circuit Judge.
The United States appeals the judgment of the United States Claims Court, 10 Cl.Ct. 31 (1986), in favor of Gibraltar Financial Corporation of California (GFC or taxpayer) for the amount of $15,119.17. Taxpayer had sought a refund of the tax which it was assessed in 1972 and 1973 on the portion of taxpayer's gain on sales of certain real property ("security property") which Internal Revenue Service determined was delinquent interest on the underlying...
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