Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $76,696.96 in petitioner's 1975 Federal income tax. The issue for decision is whether a contract executed in 1975 effected a sale of a nursing home or a lease with an option to purchase, or, in the alternative, whether the transaction was effected in 1974.
Findings of Fact
Certain facts are deemed stipulated pursuant to Rule 91(f)(3), Tax Court Rules...
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