Memorandum Opinion
FAY, Judge:
Respondent determined deficiencies of $701,828 and $128,953 in petitioner's Federal income tax for the fiscal years ending July 31, 1973, and July 31, 1974, respectively. After concessions, the only issue remaining for decision is whether petitioner, an accrual basis taxpayer, may accrue and deduct a liability arising from the transfer of participating interests in notes.
All the facts have been stipulated and are found...
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