Memorandum Findings of Fact and Opinion
TANNENWALD, Chief Judge:
Respondent determined a deficiency of $92,639 in petitioners' 1975 Federal income tax. The issues for our determination are: (1) whether petitioners are entitled to use the installment method to report their gain on the sale of stock; if not, (2) whether the sale qualifies as an open transaction.
Findings of Fact
Some of the facts have been stipulated and are found accordingly...
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