OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1956 in the amount of $18,375.14.
The only issue remaining is whether petitioners realized ordinary income by operation of section 1239, I.R.C. 1954, or long-term capital gain from the cash sale in 1956 by petitioners to a family-owned corporation of a 10-year lease on farmland commencing January 1, 1957, which lease petitioners as lessees had...
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