Memorandum Opinion
SCOTT, Judge:
Respondent determined deficiencies in the joint Federal income tax of Orville C. Wacker and Pearl Wacker in the amounts of $119,914.64 and $42 for calendar years 1974 and 1975, respectively.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision:
(1) Whether a 1974 agreement between petitioners, as the sellers of Royal Villa Garden Apartments, and...
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