Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a deficiency of $17,310.16 in petitioners' joint Federal income tax for the calendar year 1981.
After concessions, the remaining issue we must decide is whether, for purposes of computing the gross profit ratio under section 453(c), certain property purchased in part with a wraparound mortgage was in substance taken subject to an underlying mortgage. Unless otherwise indicated...
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