OPINION
CLAPP, Judge:
Respondent determined a $26,444 deficiency in petitioners' Federal gift tax for the calendar quarter ending June 30, 1981. Following concessions, the issues are (1) whether petitioners' sale of land to a family member at the interest rate set by section 1.483-1(d)(1)(ii)(B), Income Tax Regs., prevents respondent from using a higher market interest rate for gift tax purposes, and (2) if not,
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