Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency in the individual petitioners' Federal income tax for 1973 of $4,868.95 and a deficiency in the corporate petitioner's Federal income tax for 1973 of $5,828.24. The only issue for decision is which of the petitioners owned an 82.2-acre tract of land when it was sold to a third party in 1973.
Findings of Fact
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