Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $42,417.18 in the petitioners' 1960 income tax. Certain issues have been conceded by the parties. The principal question remaining is whether a certain transfer of stock represented a bona fide sale on the installment basis. If that question is answered in the affirmative, there is a further issue as to whether certain payments to the transferor were loans or...
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