Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined deficiencies of $1,034.98 for 1962 and $7,883.59 for 1963 in the Federal income taxes of Kenneth C. and Eathyl L. Hoagland, and a deficiency of $7,785.97 for 1963 in the Federal income tax of Bob and Louise F. Vincent. The cases have been consolidated, and the sole issue for decision is whether the petitioners are entitled to treat as a long-term capital gain certain payments...
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