Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in the income taxes of petitioners A. G. Homann and Anna Homann in the amounts of $10,148.95 and $10,457.70, respectively, for the taxable year 1946. The questions to be decided are (1) whether gain realized from the sale of certain houses during the year in controversy should be treated as capital gain rather than ordinary income; (2) if those houses were property used...
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