Memorandum Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1961 in the amount of $1,684.90.
The sole issue presented for decision is whether petitioners realized ordinary income or capital gain upon receipt of their interest in Tedeschi's Salaried Employee Deferred Profit Sharing Trust in the taxable year 1961.
All of the facts have been stipulated and the stipulated facts, together...
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