Memorandum Opinion
IRWIN, Judge:
Respondent determined a deficiency of $141,953 in petitioners' consolidated Federal income tax for the taxable year ending May 31, 1972.
Due to concessions by both sides, the only issues presented for our consideration are: (1) Whether the transactions herein described between petitioners and the Edward J. DeBartolo Corporation for the transfer of 175 acres of land constituted a completed sale or was, in substance...
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