PER CURIAM:
The sole question on this appeal is whether the Tax Court was clearly erroneous in finding as a fact that the taxpayers sold an interest in an oil and gas contract, thus realizing short-term capital gain, or whether, as taxpayers contend, they contributed such interest to a partnership so as to make a nontaxable exchange under Section 721 of the Internal Revenue Code. After a careful review of the record, we find that the evidence sufficiently supports...
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