These proceedings, consolidated for trial and opinion, arise from respondent's determination of a deficiency in the income tax of each petitioner for the calendar year 1946 in the amount of $15,666.45.
Two issues are presented: (1) Whether the gain realized by the petitioners, husband and wife, in 1946 from the sale of 152 lots was derived from the sale or exchange of a capital asset and therefore was taxable as capital gain, or was derived from the sale of property...
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