OPINION.
MULRONEY, Judge:
The respondent determined a deficiency in the income tax of the petitioners in these consolidated cases for the calendar year 1951 in the amount of $15,525.59. The sole issue in controversy here is whether the proceeds from the sale of certain stock, reported as income in the 1951 joint return of petitioners, can be included in that year's income when it appeared petitioners were obliged to pay back such proceeds to a claimant...
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