Memorandum Findings of Fact and Opinion.
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax for the taxable years 1957 and 1958 in the respective amounts of $4,815.46 and $176.52.
The issues for decision arise out of the sale by William D. Allison (hereinafter referred to as William) of his insurance agency for a stated consideration of $24,000 in 1957. The issues are:
(1) The cost basis of William in the Allison...
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