TUTTLE, Circuit Judge.
The issue here presented for our consideration is whether the Tax Court erred in holding that the forgiveness by a corporation of a debt owed by a stockholder, owning virtually all of its stock, resulted in the taxpayers' realizing ordinary income, as the Commissioner contends, or is gain from the sale or exchange of a capital asset if, as the taxpayers contend, they had previously entered into a contract for sale of their stock for a price...
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