OPINION.
LEECH, Judge:
This proceeding involves income tax for the calendar year 1944 in the amount of $2,939.58. Respondent claims an increased deficiency of $417.48. The sole contested issue is whether the amount received by petitioner in the taxable year on certain certificates issued by the Maple Grove Cemetery Association over the cost thereof is taxable as ordinary income or long term capital gain.
The facts have been stipulated. We...
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