Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency of $121,500.88 in the income tax of petitioners Antone and Anna A. Borchard for the taxable year 1958.
The sole issue for decision is whether the transfer by petitioners of certain parcels of land constituted a taxable sale or a nontaxable exchange.
Findings of Fact
Some of the facts have been stipulated and the Stipulation of Facts and exhibits...
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