WITHEY, Judge:
The respondent has determined a deficiency of $33,664.94 in the income tax of the petitioners for 1963. As a result of concessions made by the petitioners, the only issues for determination are the correctness of the respondent's action (1) in determining that the sale by petitioners of their business and assets did not qualify as an installment sale within the purview of section 453 of the Internal Revenue Code of 1954 and that the gain realized...
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