OPINION
STERRETT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1970 and 1971 in the amounts of $7,434.60 and $7,438.35, respectively. The issue for decision is whether petitioners, due to their failure to file a statement of election with their returns, are deprived of the benefits of section 1251(b)(4), I.R.C. 1954.
All of the facts have been stipulated and are so found. The stipulation...
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