TIETJENS, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax for taxable years 1964 and 1965 in the amounts $101,224.14 and $7,429.53, respectively. In addition, by an amendment to answer, the Commissioner proposes additional deficiencies in the amounts of $40,419.50 and $4,429.46 for 1964 and 1965, respectively. By virtue of concessions by the parties, the only issue for decision is the amount of gain or loss occasioned by the...
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