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not apprise the reviewer of the specific nature of
petitioner's claim that the interest on its purchase money
obligations is includable in adjusted income from rents,
such that rents are excluded from the computation of
personal holding company income. Nor would a review of
petitioner's returns disclose the relevant facts regarding
petitioner's claim that it held real properties for sale to
customers in the ordinary course of business, such that the
interest income was from "debts" that "represent the price
for which real property held primarily for sale to
customers in the ordinary course of its trade or business
was sold or exchanged by the corporation". Sec. 543(b)(3).
In fact, as discussed above, petitioner's returns report
just the opposite. According to petitioner's returns, its
sales of real property involve "property used in the trade
or business", as defined by section 1231(b), and "install-
ment sales", as defined by section 453(b). Thus, according
to petitioner's returns its sales of real property did not
involve real property held for sale to customers in the
ordinary course of petitioner's trade or business. See
secs. 453(l)(1)(B), 1231(b)(1)(B).
Moreover, in the case of petitioner's returns for
1989 through 1993, regulations promulgated under section
6662(d)(2)(B)(ii) and former section 6661(b)(2)(B)(ii)
set forth the method of making an adequate disclosure.
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