Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the income tax of petitioner for the taxable year ended May 31, 1961, in the amount of $80,101.72.
The issue for decision is whether the transfer by petitioner of installment obligations resulted in a capital gain and, if so, the amount thereof.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Petitioner...
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