The Commissioner determined deficiencies in income tax for 1950 and 1951 in the amounts of $6,976.66 and $1,793.06, respectively.
The first question is whether gains realized in the taxable years 1950 and 1951 from sales of real estate are taxable as ordinary income as determined by the Commissioner, or as capital gains as claimed by the petitioners. The second question is whether gain from two sales of lots is taxable in 1949, when two contracts of sales were executed...
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