OPINION
IRWIN, Judge:
The Commissioner determined a deficiency of $53,903 in petitioners' joint Federal income tax for the calendar year 1970.
The issue posed is one of first impression. It is whether the incorporation of a sole proprietorship causes a cessation of the trade or business of the individual proprietors within the meaning of Rev. Proc. 67-10, 1967-1 C.B. 585, as amplified by Rev. Proc. 70-16, 1970-1 C.B. 441, so as to require...
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