MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the taxable years 1977 and 1979 in the amounts of $65,531 and $438,128, respectively.
After concessions, the sole issue remaining for decision is whether petitioner realized a foreign currency exchange gain in 1979 in the amount of $392,707, arising from the repayment to it of a loan previously made to its Belgian subsidiary...
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