ATKINS, Judge:
Respondent determined deficiencies in income tax against the petitioners for the taxable years 1961, 1962, and 1964 in the amounts of $12,793.86, $3,227.13, and $20,006.95, respectively. Petitioners raised certain issues in their petition with regard to which they introduced no evidence and accordingly they are considered to have been abandoned. The issues remaining for decision are whether petitioners sold or otherwise disposed of certain installment...
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