Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $61,623 in petitioners' Federal income tax for 1986.
The issues for decision are: (1) Whether respondent's determination of a $1 per share basis in the stock of petitioners' corporation should be sustained, (2) whether petitioners may revoke their election out of the installment method of reporting their capital gain for 1986, and (3) whether petitioners are...
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