Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent has determined deficiencies in Federal income tax against the petitioners for the calendar year 1954 in the following amounts:
Joseph I. and Evelyn J. Lubin..... $524,681.99 Estate of Joseph Eisner and Helen Eisner ........................ $264,479.22
The issue remaining for decision is whether gain of $1,000,000 realized by petitioners on the retirement...
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