These proceedings involve deficiencies in income tax for the taxable year ended December 31, 1945, in the amount of $25,546.39 as to each petitioner. They present the question whether under the facts the sale of an interest in the partnership involved constituted the sale of a capital asset resulting in a gain taxable under section 117 (b), Internal Revenue Code. Most of the following facts were stipulated.
FINDINGS OF FACT.
The petitioners, Paul W. and...
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