Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency of $1,428.21 in the income tax liability of the petitioner for the calendar year 1946.
The only issue is whether or not a gain realized on the sale of ten houses in the taxable year is taxable as ordinary income or as long-term capital gain. Some facts were formally stipulated and are included herein by reference.
Findings of Fact
The petitioner...
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