Memorandum Opinion
LEECH, Judge:
This controversy involves a deficiency in income tax for the year 1941 in the amount of $2,590.87. The only issue is whether the gain realized by decedent from the sale of two-sixths [two-thirds?] of an undivided three-sixths interest in a partnership is a capital gain or an ordinary gain for Federal income tax purposes. All the facts have been stipulated and are adopted as our findings of fact. They may be summarized as...
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