HOYT, Judge:
This case involves a deficiency in income tax for the taxable year 1961 amounting to $3,256.75. The sole question for our decision is whether the sum of $13,125, part of a greater amount received by petitioners from Citizens Bank & Trust Co. of Campbellsville, Ky., represented gain from the sale or exchange of a capital asset, or, as respondent has determined, ordinary rental income.
FINDINGS OF FACT
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