Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent has determined deficiencies in petitioners' Federal income tax for the taxable years 1971 and 1973 in the amounts of $2,212.96 and $6,866.16, respectively.
The issue for our decision is whether satisfaction of a mortgage out of the proceeds of the sale of the mortgaged property reported on the installment basis under section 453
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