Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated June 6, 1978, respondent determined a deficiency of $62,282.48 in petitioners' Federal income taxes for their 1974 tax year. The sole issue for our determination is whether the petitioners, in the year of sale, received payments in excess of 30 percent of the selling price of Prairie View Mobile Village, thereby disqualifying the sale from installment sales treatment under...
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