SIMPSON, Judge:
The Commissioner determined a deficiency of $24,738.96 in the petitioner's 1971 Federal income tax. The issues for decision are: (1) Whether a transaction in which a partnership purported to sell property is to be treated as a sale for Federal income tax purposes; (2) whether amounts designated as "points" and prepaid interest in the sale agreement should be treated as interest for Federal income tax purposes, or whether some portion of them...
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