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the amount of petitioner's adjusted income from rents
constitutes 50 percent or more of the adjusted ordinary
gross income and, pursuant to section 543(a)(2),
petitioner's rents are not taken into account in computing
personal holding company income. In that event, petitioner
does not qualify as a personal holding company in any of
the years in issue because the amount of petitioner's
personal holding company income would not amount to at
least 60 percent of its adjusted ordinary gross income.
Sec. 542(a). Otherwise, if the interest on purchasers'
purchase money obligations is not treated as "rents", then
petitioner's rental income would be taken into account in
computing personal holding company income because the
amount of petitioner's adjusted income from rents would
constitute less than 50 percent of the adjusted ordinary
gross income. See sec. 543(a)(2)(A). In addition,
petitioner's interest income would be taken into account in
computing personal holding company income. See sec.
543(a)(1). As a result, in that event, petitioner would
qualify as a personal holding company in each of the years
in issue.
Petitioner contends that the interest received on its
purchase money obligations should be included in adjusted
income from rents because "Petitioner was in the real
estate operating business buying, improving, renting and
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