Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
In these consolidated proceedings respondent determined deficiencies in income tax for the calendar year 1945 of $1,616.07 for R. W. Milner, Jr. and $1,436.20 for Johnnie Donoho Milner. The only issue for decision is whether the profits from the sale of certain oil and gas interests in 1945 were taxable as ordinary income or capital gains. Disposition of an issue with regard to medical and dental expense...
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