OPINION
STERRETT, Judge:
The respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1969 in the amount of $184,914.56. One issue having been settled the sole remaining issue is whether petitioner realized additional income of $318,108.99 upon the expiration of an agreement with Tascosa Gas Co., and if so, whether such income was realized in 1969 or 1970.
All of the facts have been stipulated and are so found...
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