OPINION
FAY, Judge:
Respondent determined a deficiency in the income tax of petitioner for the taxable year beginning November 12, 1964, and ending October 31, 1965, in the sum of $1,343.77. The sole issue for decision is whether in computing gain (or loss) realized from the sale of property, petitioner, who previously deducted the selling expenses incurred in such sale as administration expenses on its estate tax return, is precluded by section 642...
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