JONES, Circuit Judge.
In 1943, Burrell Groves, Inc., a corporation, herein called the taxpayer, sold a citrus grove and equipment to Eugene J. Burrell and Alice W. Burrell, husband and wife, who owned all of taxpayer's capital stock. The properties sold had a cost basis of $136,311.50. The sale price was $187,590.00. The purchasers paid taxpayer $5,340.00 in cash upon closing and gave their note to taxpayer bearing four per cent interest and payable in equal annual...
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