Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable years 1961 and 1962 in the amounts of $1,114.45 and $39,110.69, respectively.
The issues presented for our consideration are:
(1) Whether the petitioners realized long-term capital gain of $274,613.21 on the sale of the Stable Property land in the taxable year 1962, instead of the net gain of $227,164...
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