EKMAN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1972 and 1973 in the amounts of $125,887.33 and $17,389.20, respectively.
Due to concessions by petitioners, the sole issue for decision is whether amounts received by petitioner Jonas Barenholtz were distributions by a partnership to a partner taxable pursuant to section 731 or proceeds from the sale of 75 percent of petitioners' interest in two apartment buildings...
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