Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency of $586,389 in petitioner's Federal income tax for its taxable year ending March 31, 1983. The issue for decision is whether a payment received by petitioner from the "sale" of an "option" is taxable as ordinary income or capital gain.
Findings of Fact
Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits...
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