ATKINS, Judge:
The respondent determined a $2,211.21 deficiency in income tax against the petitioners for the taxable year 1963.
The only issue for our decision is whether petitioners are entitled to deduct as a bad debt the amount of $3,693.61, the difference between a $15,031.81 note they received from the purchaser of their home at the time of its sale in 1962 and $11,338.20 (cash of $5,031.81 and a note for $6,306.39) which they received in substitution...
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