Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax for 1949 of $2,240.38 and for 1950 of $7,791.72, of which $1,696.32 and $7,370.68, respectively, remain in dispute. The unconceded items involve two issues: (1) whether certain parcels of real estate sold were capital assets, and (2) whether collections on certain notes and contracts were properly reported as to basis and type of income.
Findings...
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