Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income taxes in the amounts of $2,167.14 for 1948 and $504.94 for 1949.
The only question for determination is whether the gains from the sale of certain subdivided real estate are taxable as ordinary income as determined by the Commissioner or as capital gains as claimed by the petitioners.
[Findings of Fact]
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