The respondent determined a deficiency of $24,101.35 in the income tax of the petitioners for 1944. The issues are: (1) Whether a portion of the proceeds received by petitioner M. Gladys Watson from the sale of her one-third interest in a citrus grove with the growing fruit thereon is to be allocated to the fruit and regarded as ordinary income, (2) if so, what portion is to be so allocated, and (3) whether the expenses of the sale should also be allocated between the fruit...
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