MEMORANDUM FINDINGS OF FACT AND OPINION
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the year 1989 in the amount of $21,037.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue to be decided is whether recognition of any portion of the gain...
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