TRAIN, Judge:
Respondent determined a deficiency of $412.36 in the petitioners' income tax for the calendar year 1956. The question presented is whether gain realized upon the receipt of a payment made under a contract providing for the sale of a public accounting practice is capital gain or ordinary income.
FINDINGS OF FACT.
Some of the facts are stipulated and are hereby found as stipulated.
Petitioners are individuals, husband and...
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