Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $15,929.09 in the income tax of the petitioner for the year 1952. The sole issue is the amount of gain realized by the petitioner in 1952 on the sale of an installment obligation received in 1934 upon the sale of real property, which computation turns upon the value of an agreement to purchase certain property, certain plans and specifications for a theatre building, and a Keith franchise...
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