Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency in petitioners' income tax for 1957 in the amount of $12,589.23. The parties have agreed on stipulation that respondent is entitled to claim an increased deficiency for 1957 in the amount of $1,827.56.
The issues presented for our decision are (1) whether petitioners realized ordinary income or capital gain from a transaction purporting to be a disposition...
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