Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined a deficiency of $10,602.80 in the income tax of petitioners for the taxable year ended December 31, 1950 and determined an addition to tax of $643.82 for substantial underestimation.
Two questions are presented for decision: (1) whether petitioners are entitled to have the gain from the sale of land taxed to them on the installment basis; and (2) whether petitioners are liable...
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