HAMLEY, Circuit Judge.
Frank H. Gilbert and his wife, now Hazel P. Peterson, filed a joint income tax return for the calendar year 1949, in which the profit on a sale of certain stock was reported on the installment basis. The Commissioner of Internal Revenue thereafter determined that the profit could not be so reported, and notified the taxpayers of a tax deficiency in the amount of $47,603.77. In a deficiency redetermination proceeding initiated by the taxpayers...
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