Memorandum Findings of Fact and Opinion
These consolidated proceedings involve deficiencies in income tax for the year 1946 of $3,868.24 and for the year 1947 of $2,405.16 determined against Horace E. Oliver (hereinafter referred to as the petitioner), and in like amounts for such years determined against his wife, Kathleen Oliver.
The issue to be decided is whether gain realized from the sale of certain lots in 1946 and 1947 is taxable as a long-term capital...
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