Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined a deficiency of $4,641.09 in the petitioner's income tax for the year 1946. The petitioner, in its income tax return for 1946, reported a net long term capital gain of $88,023.68. The gain was realized, principally, from the sale by the petitioner in 1946 of 61 defense housing units, together with some furnishings and fixtures. The respondent determined that the entire amount...
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