OPINION
EKMAN, Judge:
Respondent determined a deficiency of $11,206.60 in petitioners' Federal income taxes for 1976. The sole issue for our decision is whether that portion of gain from the sale of property, which is attributable solely to inflation, is income within the meaning of the 16th Amendment.
All the facts have been stipulated and are so found. The stipulation of facts and exhibits attached...
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