MURDOCK, Judge:
The Commissioner determined deficiencies of $8,767.22 and $51,776.54 in income tax of the petitioners for the years 1952 and 1954. One of the adjustments which he made for 1954 was to add $126,617.44 to income with the following explanation:
(a) It has been determined that you realized a long term capital gain in 1954 of $253,234.88 as the result of the transfer by you of 126...
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