Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in petitioners' income tax in the amount of $12,717.72 for the taxable year 1953.
The issues for decision are (1) whether the initial payments received by petitioners on the sale of real property were not in excess of 30 per cent of the sales price thereof so as to permit their reporting of the gain on the sale on the installment method under section...
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