DENMAN, Chief Judge.
Petitioners, husband and wife filing joint returns, seek a review of the Tax Court's findings and decision of the income tax liability of petitioners for the year 1948. Since all the pertinent transactions were by the husband he is hereafter called petitioner.
The Tax Court found that at all pertinent times petitioner was in the business of holding and selling land.
On April 1, 1948, petitioner transferred certain land to a corporation...
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