Memorandum Opinion
LEMIRE, Judge:
These proceedings involve income tax deficiencies for 1946, 1947, and 1948 in the respective amounts of $167.60, $278.40 and $120.28. The sole issue, which is common to all the years involved, is whether petitioners' gains from the sale of livestock are taxable as capital gains or as ordinary income. The proceedings were consolidated for hearing and opinion and were submitted on a written stipulation of facts, which is incorporated...
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