Memorandum Findings of Fact and Opinion
The taxes in controversy are income taxes for the taxable years ended December 31, 1940, and December 31, 1941. Petitioner's income tax returns for these periods were filed with the collector of internal revenue at Birmingham, Ala.
Petitioner sold certain real estate in 1940 and reported the gain as capital gain. Respondent has determined that this gain should be treated as ordinary income and has determined a deficiency...
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