The respondent has determined deficiencies in income tax against the petitioner for the years 1939 and 1940 in the respective amounts of $2,389.66 and $3,581.73.
The only question presented is whether the petitioner's tax liability for 1939 and 1940, on profit from sales of property, should be computed under the capital gains provisions of section 117 or under ordinary income provisions of section 22 of the Internal Revenue Code.
FINDINGS OF FACT.
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