Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The Commissioner determined deficiencies in the income taxes of the petitioners for the calendar years 1958 and 1959 in the amounts of $513.64 and $861.47, respectively.
The issues for decision are:
1. Where petitioners entered into a contract with a third party for the sale of real estate, under which they retained title to the property pending the buyer's payment of the purchase price...
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