JONES, Circuit Judge.
The appellants, husband and wife, who will herein be called the taxpayers, owned and operated a citrus grove and the equipment required in the operation of it. The grove and equipment were sold on July 2, 1945, for $299,000. The sales price exceeded the adjusted cost basis by $129,551, as was shown by a partnership income tax return filed by the taxpayers. They reported this excess of sales price over cost in their Federal income tax returns...
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