COHEN, Judge:
Respondent determined deficiencies of $11,516.14 and $1,167,201.84 in petitioner's Federal income taxes for the fiscal years ended October 31, 1984 and 1985, respectively. The sole issue for decision is whether section 453(e) applies to certain sales of real property by petitioner.
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue, and all Rule references...
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