Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable year ended December 31, 1959, in the amount of $10,033.79.
The only issue for decision is whether petitioners are entitled to treat a 1959 sale of realty on the installment basis pursuant to section 453, Internal Revenue Code of 1954, on an amended joint Federal income tax return...
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