Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Petitioner was a barter exchange operated as a vehicle for the exchange of goods and services among its members.
The primary issues for decision are (1) whether petitioner realized income on the receipt of property from members in exchange for the issuance of trade units, and (2) whether petitioner realized income on the sale of property to exchange members for trade units.
As discussed...
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