Respondent has determined deficiencies in income tax for the years 1944 and 1945 in the amounts of $3,051.36 and $7,100.90, respectively. Respondent determined that the sale by petitioner of certain whiskey warehouse receipts in 1944 and of certain real estate in 1945 were not the sale of capital assets within the meaning of section 117 (a) of the Internal Revenue Code, and included the entire amounts of gains from such sales in petitioner's income for the respective years...
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