Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent asserted deficiencies in petitioners' income tax for the taxable years 1965, 1966, and 1967 in the amounts of $70,026.74, $9,331.07, and $6,704.46, respectively. Concessions having been made, the sole issue to be decided is whether a sum of money received by Gail Hummel is an amount realized on a sale or the proceeds of a loan.
Findings of Fact
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