Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $7,039.86 in petitioners' Federal income tax for the year 1969.
At issue is whether, under the particular circumstances of this case, respondent's agent, the Nashville District Director, abused his discretion in declining to grant the petitioners an extension of time in which to replace property involuntarily converted. The answer turns upon whether the petitioners...
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