TRAIN, Judge:
In these consolidated proceedings, respondent determined deficiencies in income tax of $328,563.55 in docket No. 81795 for 1955 and of $22,668.56 and $28,307.22 in docket No. 86259 for 1956 and 1957, respectively. These deficiencies arise mainly from respondent's inclusion in petitioners' 1955 and 1956 taxable income of the outstanding balance of certain first trust deed notes which petitioners received in years prior to 1955, and in 1955 and...
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