ROSS, Senior Circuit Judge.
The Estate of Charles A. Juden and Cleo M. Juden (Taxpayers) appeal from a decision of the United States Tax Court finding Taxpayers liable for an income tax deficiency in the amount of $78,599 for the taxable year 1979. On appeal the Taxpayers argue first that a taxable event never occurred, and second, even if a taxable transaction had occurred, the tax deficiency was based on the Tax Court's erroneous determination of the Taxpayers'...
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