Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1980 and 1981 in the respective amounts of $382,415 and $75,699. Concessions having been made, the issue remaining for decision is whether tax-exempt bonds were substituted for the purchase money promissory note (the purchase note) in controversy or whether the purchase note was retired in a taxable event under section 453...
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