OPINION
WITHEY, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1961 and 1962 in the amounts of $12,840.49 and $221.84, respectively. Petitioners have conceded some of the issues raised by their petition, leaving the following issues to be decided:
(1) Whether the transfer by petitioners in 1961 of the assets and liabilities of their sole proprietorship to their controlled corporation constituted...
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