Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the petitioners' income tax for the calendar year 1963 in the amount of $951.27.
Some of the issues raised in the pleadings have been disposed of by agreement of the parties, leaving for our decision the following:
Whether $5,000 received by petitioner Robert E. Ronhovde as his distributive share of the gain by a partnership realized from the sale...
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