OPINION
MULRONEY, Judge:
Respondent determined a deficiency in petitioners' 1954 income tax in the amount of $1,425.69.
Petitioner, Jerome A. Wiltse, sold his one-third interest in a two-man partnership in November of 1953. The issue here is the correct tax on the money Wiltse received in 1954 from his 1953 sale of his partnership interest.
Jerome A. Wiltse, who will be referred to as petitioner, and his wife, Lillian, reside in Santa...
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