Memorandum Findings of Fact and Opinion
These proceedings, consolidated for purposes of hearing and opinion, involve deficiencies in income tax for the calendar year 1946 of $11,181.37 for H. Truman Browne and $11,162.58 for his wife, Bettie Browne.
The issue to be determined is whether the gain from the sale of certain residential properties and an unimproved lot were properly treated by petitioners as a long-term capital gain; or whether such gains, as...
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