Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves deficiencies of $7,214.90, $2,673.22 and $890.05 in income taxes for the years 1945, 1946 and 1947, respectively. All of the issues raised by the petition were abandoned by the petitioner at the hearing except the question of whether gains realized by the petitioner in 1945 and 1946 from sales of improved real property are taxable as ordinary income or as capital gains. Petitioner...
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