TIETJENS, Judge:
The Commissioner determined a deficiency in petitioners' income tax for the year 1950 in the amount of $21,947.14 and made additions to the tax under section 294 (d) (1) (A) and (d) (2) of the Internal Revenue Code of 1939, in the respective amounts of $1,970.15 and $1,316.83. Certain adjustments made by the Commissioner were not contested. There is one issue left for our consideration, namely, whether petitioners realized income from a transaction...
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