Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the petitioner's income tax of $8,991.61 and $14,472.95 for the calendar years 1948 and 1949. The only issue for decision is whether six properties sold by the petitioner during the taxable years were held for investment or "primarily for sale to customers in the ordinary course of his trade or business" within the meaning of section 117(a)(1).
Findings of Fact
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