Memorandum Findings of Fact and Opinion
The petitioners have asked for a redetermination of the deficiency found by the respondent in the amount of $2,633.86 for the calendar year 1938. The main issue is whether cash in the sum of $29,000 and property of the value of $4,000 constitute ordinary income and are taxable as such or are capital gain. The facts have been stipulated by the parties and we will set them forth in such detail as is necessary to present the...
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