SCOTT, Judge:
Respondent determined deficiencies of $91,323 and $10,658 for the calendar years 1975 and 1976, respectively, in the Federal income tax of Arthur and Selma Long and deficiencies in the amount of $153,443 and $4,761 for the calendar years 1975 and 1976, respectively, in the Federal income tax of Dave and Bernette Center.
After concessions by the parties, the issues for decision are: (1) Whether the exchange of an interest in a Texas general partnership...
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