Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a $59,983.74 deficiency in petitioners' Federal income tax for the taxable year ended June 30, 1974. After concessions, the issues for decision are:
1. Whether any portion of the sale price of certain assets must be allocated to goodwill.
2. Whether petitioners may report any gain from the sale of those assets under section 453(b);
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