Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency of $932,189 in petitioner's Federal income tax for 1983.
Initially, we must determine the character of the gain (capital gain, as respondent contends, or ordinary income, as petitioner contends) realized by petitioner from the sale of a note it received in connection with the sale of its interest in Florida real estate. If such gain is determined to be ordinary...
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