Memorandum Sur Order
STERRETT, Judge:
On November 8, 1974, petitioners filed a document entitled "Motion for Reconsideration of Findings and Opinion" pursuant to Rule 161, Tax Court Rules of Practice and Procedure. This motion was served upon respondent and on December 17, 1974, he filed his objections thereto and a memorandum brief in support thereof.
One of the issues presented to this Court by the parties in the above-entitled proceeding [
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