Memorandum Findings of Fact and Opinion
FISHER, Judge:
The respondent determined deficiencies in petitioners' income tax for the taxable years 1951 and 1952 in the amounts of $7,580.39 and $9,963.58, respectively, on the ground that the receipt of $25,000 during each of the years in issue, pursuant to a so-called lease-option agreement, was rental income rather than payments on an installment sale as reported by petitioner.
The sole issue presented...
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