STERRETT, Judge:
Respondent, on July 23, 1976, issued a statutory notice in which he determined a deficiency in petitioners' Federal income tax for the calendar year 1971 in the amount of $346,075. After concessions by the parties, the sole issue remaining for our determination is whether petitioners are entitled to report the gain resulting from the sale of 42,000 shares of Cooper Laboratories, Inc., common stock on the installment basis under section 453...
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