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YATES HOLDING CORPORATION v. COMMISSIONER

Docket No. 8240-78.

39 T.C.M. 303 (1979)

T.C. Memo. 1979-416

Yates Holding Corporation v. Commissioner.

United States Tax Court.

Filed October 3, 1979.

Attorney(s) appearing for the Case

David K. Diebold, 15 Court Street, Buffalo, N.Y., for the petitioner. Anthony Bruce, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent determined the following deficiencies in petitioner's Federal income taxes:

  Year            Deficiency

  1972 ........... $ 5,953
  1973 ...........   6,927
  1974 ...........  17,009
  1975 ...........   5,932

The only issue presented is whether a transaction in which petitioner as mortgagee received half of the outstanding balance of a mortgage constituted a compromise of a debt...

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