OPINION
PER CURIAM:
The Tax Court, concluding that taxpayers' transfer of their vendors' interest in an installment contract to an irrevocable trust constituted a disposition within the purview of 26 U.S.C. § 453(d) and thus subjected the gain to immediate recognition, affirmed the Commissioner's determination of deficiencies in their income tax.
A review of the record discloses that all factual determinations...
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