OPINION
SCOTT, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable year 1960 in the amount of $9,125 and an addition to the tax under section 6654 of the Internal Revenue Code of 1954 for underpayment of estimated tax in the amount of $83.95.
The two issues raised by the pleadings which remain for decision are:
(1) Whether petitioner W. Stanley Barrett realized long-term capital gain or ordinary...
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