Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined the following deficiencies in income tax: 1936, $28,552.41; 1937, $28,074.17; 1938, $25,547.56; 1939, $203,106.10.
He included in the taxpayer's 1936, 1937, and 1938 income amounts of semi-annual installments and interest which were received by his assignees of interests in a contract and in 1939 income, the installments remaining unpaid...
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