SIMPSON, Judge:
The Commissioner determined a deficiency of $755.34 in the petitioners' 1969 Federal income tax. The ultimate issue in the case is the amount of gain or loss realized by the petitioners on the sale of certain real property. To answer that question, we must first decide how to compute the petitioners' basis in the property under section 1038(c) of the Internal Revenue Code of 1954, since they had previously sold
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