Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined a deficiency in income tax against the petitioners for the taxable year 1952 in the amount of $4,143.86. The question for decision is whether the proceeds from the sale of the capital stock of a corporation may be reported on the installment basis, under the provisions of section 44(b) of the Internal Revenue Code of 1939.
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