MULRONEY, Judge.
The respondent determined deficiencies in petitioner's corporate income tax for its fiscal years ended May 31, 1956, 1957, and 1958 of $13,454.03, $115,504.22, and $54,503.89, respectively. Petitioner is engaged in the mortgage loan business. During the years in question it sold some mortgages to the Federal National Mortgage Association, and, pursuant to the Association's requirements, it received, as the proceeds of the sales, cash and shares...
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