Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies of $83,063.67 and $124,823.25 in petitioner's income tax for the taxable years ending March 31, 1962, and March 31, 1963, respectively. The only issue for decision is whether petitioner must be charged with all or merely one-half of the gain realized on the sale of a "Lease and Option Agreement" on September 8, 1961; petitioner contends...
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