DAWSON, Judge:
Respondent determined deficiencies in the income tax of petitioners for the years 1958 and 1959 in the amounts of $1,776.01 and $1,625.03, respectively. The primary issue for decision is whether certain amounts received by petitioners during the taxable years 1958 and 1959 from the M & W Gear Co., Inc., qualify for capital gains treatment under the provisions of section 1235, Internal Revenue Code of 1954.
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