SHIELDS, Judge:
Respondent determined deficiencies in petitioners' income tax for 1978 and 1979 in the respective amounts of $16,086.83 and $1,488.37. After concessions by the parties, the issue remaining for decision is whether certain payments received by petitioners under a long-term contract for the sale of timber must be treated as ordinary income as contended by the respondent, or as income from capital gains under section 631(b)
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