PARR, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for taxable years 1988 and 1989 in the amounts of $387 and $40,482, respectively. In the answer, respondent asserted that petitioners were liable for an addition to tax pursuant to section 6662(a).
After concessions, the issues for decision are: (1) Whether for 1989 petitioners realized $571,179 on the foreclosure sale of certain real property...
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