Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined the following deficiences in petitioner's income tax:
Year Deficiency 1970 ........ $8,753.83 1971 ........ 4,037.14 1972 ........ 1,250.91
Due to concessions by petitioner, the issues remaining for decision are:
1. Whether petitioner realized taxable gain in 1970 or...
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