OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $392.16 in the income tax of the petitioners for 1949 and an addition of $46.72 under section 294 (d) (2) of the Internal Revenue Code for substantial understatement of estimated tax. The issues are whether the amount collected on accounts receivable after the sale of the rest of the business was ordinary income or capital gain to taxpayers on a cash receipts basis and whether the...
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