OPINION
RAUM, Judge:
The Commissioner determined a deficiency in petitioner's fiscal 1981 income tax in the amount of $28,540. At issue is the proper amount of gain to be recognized in petitioner's 1981 tax year on its installment sales of land in which "wraparound mortgages" are taken as part of the payment price.
The parties agree that the governing statutory provisions are in section 453(c) of the Code. That section provides that the income...
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