BRUCE, Judge:
Respondent determined deficiencies in income taxes of the petitioner for the years 1957 and 1958 in the amounts of $413.74 and $17,669.70, respectively.
We are called upon to determine (1) the proper allocation of the basis of a single tract of real estate to two portions of that tract, one of which was sold in 1957, the other in 1958, and (2) whether any part of an amount of $50,000 placed in escrow for improvements to the retained center...
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