The Commissioner determined a deficiency of $7,946.81 in the petitioner's income tax for its fiscal year ended April 30, 1950. The only issue for decision is whether the petitioner, as purchaser of a hotel, is liable for the net income from the property for a period prior to the conveyance of title to it when the contract provided for the allocation of operating expenses to the petitioner as of an earlier date and for the crediting of the net income, if any, from the hotel...
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