OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1953 in the amount of $34,525.87.
Petitioners assign as error the following:
In determining the tax liability of petitioners for the calendar year 1953, the Commissioner erroneously converted a long-term capital gain realized from the sale by petitioners of a partnership interest, to ordinary income from the subject partnership.
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