Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $4,913.26 in the income tax of the petitioners for 1951. The Commissioner, in determining the deficiency, added $26,088.89 to income reported on the return and eliminated a reported capital gain on the sale of cattle in the amount of $13,313.91. He explained that the $26,088.89 represented ordinary income realized from the sale of cattle held for less than one year and the elimination...
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