PER CURIAM:
Taxpayers appeal from a Tax Court ruling that they did not qualify under I.R.C. § 1201 for a twenty-five percent capital gains tax rate on their sale of stock. 1976 T.C.M. ¶ 76,362 (P-H). The narrow issue before us is whether the Tax Court erred in concluding that the taxpayers had not sold their stock pursuant to a binding contract in effect on November 9, 1969. We cannot say that the Tax Court's finding of fact on this issue is clearly erroneous...
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