Memorandum Opinion
TIETJENS, Judge:
Respondent determined the following deficiencies in petitioner's income taxes:
Addition to Tax Year Deficiency Sec. 6653(a) 1971 ........ $73,941.21 $3,697.06 1972 ........ 4,684.57 234.23
The sole issue remaining for our determination is whether petitioner realized taxable income when he transferred appreciated property...
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