OPINION
DAWSON, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1961 in the amount of $1,960.50.
The only issue for decision is whether the petitioners, who sold their sole proprietorship business in 1961, received payments in excess of 30 percent of the selling price during that year so that they were precluded from using the installment method provided by section 453
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