OPINION
SKOPIL, Chief Judge:
On September 1, 1970, the plaintiff taxpayers, Bert and Virginia Crosswhite, sold a 68.24-acre parcel of real property to their wholly-owned corporation for $550,000. On their federal income tax return for taxable year 1970, they reported the income from the installment payment received in 1970 as capital gain. The Internal Revenue Service (IRS) assessed a deficiency, finding that the property had been held by the Crosswhites...
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