Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for their taxable years 1973 and 1974 in the amounts of $316,677 and $21,999, respectively. After concessions, the issues are: (1) Whether the consideration petitioners received for contiguous properties referred to herein as the Serdar Property and Wadsworth Farm included a prepayment penalty, so as to preclude installment sales...
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