Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for her 1982 and 1983 taxable years in the amounts of $14,062.18 and $7,752.06, respectively. After concessions, the sole issue for decision is the proper tax treatment to be given certain ground lease rent paid by petitioner in the years at issue.
We find that petitioner's sale, reacquisition, and resale of the property involved...
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