Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income tax and an addition to tax as follows:
Addition to tax Taxable Year Deficiency Sec. 6653(a) 1967 ........... $443.44 $22.17
The issues presented for our consideration are: (1) Whether the petitioner's basis in certain real estate was less than the price for which...
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