FORRESTER, Judge:
Respondent has determined a deficiency in the income tax of petitioners for their taxable year 1951 in the amount of $26,657.18. The issue is whether respondent erred in disallowing to a certain gain realized by petitioners the treatment provided in section 117 (b) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
Petitioners, husband and wife, reside in Elizabeth, New Jersey. Their return...
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