Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency in income taxes of the petitioners for 1951 in the amount of $48,494.77. The only issue for decision is whether the proceeds from the sale of an oil payment was a long-term capital gain as reported by the parties or was ordinary income as determined by the Commissioner. The facts in the case have been submitted on a stipulation of facts which has been adopted as the findings of fact...
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