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Taxpayer purchases a previously-originated loan on the secondary market and holds for investment. Although Taxpayer is a domestic (i.e., US) resident, the borrower is a

Taxpayer purchases a previously-originated loan on the secondary market and holds for investment. Although Taxpayer is a domestic (i.e., US) resident, the borrower is a resident of India. What is the source of the gain on a sale of the loan

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