Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income tax for the calendar year 1953 in the amount of $37,850.50. By amended petition the petitioners claim an overpayment of $12,985.06. The sole issue concerns the tax effect of a transaction involving gas and oil interests. The taxpayers filed a joint return for 1953 with the director of internal revenue at Dallas, Texas. Some facts are stipulated.
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