ATKINS, Judge:
The respondent determined a deficiency of $4,878.75 in income tax for the taxable year 1964. The only issue presented is whether the petitioner is entitled to report the gain upon the sale of his insurance agency in 1964 upon the installment method under section 453(b) of the Internal Revenue Code of 1954.
FINDINGS OF FACT
Some of the facts have been stipulated and the stipulations are incorporated herein by this reference....
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