Memorandum Opinion
TIETJENS, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Year Deficiency 1975 ........ $187,380.83 1976 ........ 1,780.19
The issues for our determination are (1) whether petitioner's sale of a 55-mile interconnection transmission line in 1975 constituted an extraordinary retirement under section 167(m)
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