Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency in petitioners' income tax for the taxable year 1969 in the amount of $37,190.69. Several issues have been settled by the parties. The remaining issue is apportionment of the cost of an entire tract of real property among its several parts for purposes of determining gain realized on the sale of a portion of such property...
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