MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
Respondent determined a deficiency of $6,974 in petitioners' 1994 Federal income tax and an addition to tax under section 6651(a)(1) of $286.
Respondent conceded the addition to tax under section 6651(a)(1). Petitioners conceded all other adjustments in the notice of deficiency. The sole issue for decision is whether petitioners are entitled to report gain realized...
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