Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in petitioner's income tax for the taxable year 1973 in the amount of $190,407. After concessions, the issues for decision in this case are (1) whether petitioner realized income by reason of a discharge of indebtedness in 1973 and (2) whether the statute of limitations bars the assessment and collection of tax in this case.
Findings of Fact
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