First National Bank in Albuquerque v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
1Opinion of the Court
STEPHEN H. ANDERSON, Circuit Judge.
The First National Bank in Albuquerque (“First National” or “Bank”) appeals from a decision of the United States Tax Court holding that the Bank realized taxable income in 1980 as the result of a disposition of an installment obligation within the meaning of § 453(d) of the Internal Revenue Code of Í954 (“Code”). We affirm on the basis of §§ 453(a) and (b) of the Code because the installment obligation was paid in full, in cash, in 1980.
BACKGROUND
On July 9, 1979, First National sold its old bank building and the underlying real estate in Albuquerque, New…
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