MEMORANDUM OPINION
RAUM, Judge:
The Commissioner determined deficiencies of $10,749 and $840 in petitioner's 1991 and 1992 Federal income taxes, respectively. The parties have stipulated to a number of issues, all in accordance with the notice of deficiency. The remaining issues are: (1) Whether petitioner realized a capital gain upon disposition of certain property as a result of its seizure by the Federal Deposit Insurance Corporation (FDIC); (2) whether...
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