The Commissioner determined a deficiency in the income tax of petitioners, Anton L. Trunk and Clara P. Trunk, for the taxable year 1950 in the amount of $47,431.46. This deficiency insofar as it is herein contested results from respondent's determination that the receipt during 1950 of $80,000 by petitioner Clara P. Trunk from a lessee constituted ordinary taxable income. No part of this sum was reported as income by petitioners in their return for the taxable year.
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