Memorandum Opinion
VAN FOSSAN, Judge:
Respondent determined a deficiency of $8,601.82 in petitioner's income tax for the year 1947, consequent on his holding that a gain of $30,201.45 received by petitioner on the sale of 1,875 ewes was taxable as ordinary income and not as long-term capital gain, petitioner having returned it as long-term capital gain. Respondent added the sum of $15,100.73 or 50 percentum of the gain to petitioner's adjusted gross income...
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