Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This is a proceeding for redetermination of a deficiency in income tax of $21,404.26 of the petitioners for the year 1948.
The only question for decision is whether the profit made on a sale of Government surplus airplane engines, parts, and tools owned by petitioners constituted ordinary income or long-term capital gain.
Findings of Fact
The petitioners, hereinafter called...
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