OPINION.
BLACK, Judge:
The Commissioner has determined a deficiency in petitioners' income tax for the year 1951 of $31,694.42. The deficiency is due to an adjustment made to the income as reported on the joint return filed by petitioners for the calendar year 1951. This adjustment was: "(a) Ordinary income [increased] $50,590.91." This is explained in the deficiency notice as follows:
(a) In your income tax return for the calendar year 1951...
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