Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioners' income tax:
Taxable Year Deficiency 1966 ............. $ 473.92 1967 ............. 9,832.95
We are asked to determine whether payments received by petitioners under a "leaseoption" agreement should be characterized as rental income or income from the sale of property used in petitioner...
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