OPINION.
RAUM, Judge:
Respondent has determined a deficiency in the Federal income tax of the petitioners for the taxable year 1950 in the amount of $13,340.28. The sole remaining issue is whether respondent erred in refusing to permit petitioners to elect to report on the installment basis the gain from a sale of real property in 1950.
The facts have all been stipulated, and the stipulation is incorporated herein as our findings.
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