Memorandum Findings of Fact and Opinion
FAY, Judge:
The Commissioner determined deficiencies of $931.12 and $588.25, respectively, in petitioners' income tax for the calendar years 1958 and 1959. The sole issue remaining for decision is whether William T. Wheeling correctly reported certain amounts received by him as long-term capital gains arising from the sale of a partnership interest pursuant to section 741
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