Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $1,830.52 in income tax for 1948. The only issue for decision is whether an agreed gain of $15,000 was ordinary income or long-term capital gain.
The Commissioner takes the position that the petitioner owned no capital assets from which the gain arose.
The following findings of fact are made from the evidence: The petitioner owned a 10 per cent interest in the...
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