FEATHERSTON, Judge:
Respondent determined deficiencies of $23,464.99 and $111,759.41, respectively, in petitioners' 1967 and 1968 Federal income taxes. The issues for decision are:
(1) Whether a partnership, of which petitioner was a member, made an arm's-length sale in 1967 when it conveyed an undivided 10-percent interest in its shopping center real estate to certain trusts; if so,
(2) Whether the loss realized on the 1967 transaction arose...
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