Court of Appeals for the Fourth Circuit April 29, 1963, 8736_1 (Commissioner of Internal Revenue v. Morton Liftin and Sylvia Liftin)

ALBERT V. BRYAN, Circuit Judge.

Gain was not realized by the respondent taxpayers, the Tax Court has decided, in the discount of certain second mortgage monthly payment notes until after the cost of a note or notes was fully restored, either through payments or foreclosure.