MULRONEY, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the fiscal year ended October 31, 1953, in the amount of $3,580.29. The issue is whether the petitioner must include in income certain portions of the purchase price of sales of real estate made in the fiscal year 1953, where such portions are placed in a savings account with the financing institution and assigned as collateral security to protect the financing institution...
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