Memorandum Findings of Fact and Opinion
Respondent determined a deficiency of $1,589 in the income tax of petitioners for the calendar year 1948.
The single issue for decision is whether petitioner Harry W. Goodman's share of the gains of a joint venture from the sale of realty received in the taxable year is entitled to capital gains treatment under section 117 of the Internal Revenue Code, or whether it is taxable as ordinary income.
Other adjustments...
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