The respondent has determined a deficiency of $35,249.36 in the petitioner's income tax liability for the taxable year ended December 31, 1946. The petitioner contests that part of the deficiency resulting from the respondent's determination that $66,329.91 of the $77,021.62 gain on the sale of a building and land was gain from the sale of a noncapital asset and taxable as ordinary income rather than as capital gain.
FINDINGS OF FACT.
The petitioner is an...
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