Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $48,000 in petitioner's Federal income tax for 1971. The sole issue for resolution is whether $100,000 received by petitioner in 1971 constitutes ordinary income or a reduction of petitioner's basis in certain property.
Findings of Fact
Some facts were stipulated and are so found.
Petitioner is a California corporation which maintained its...
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