Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in income tax for the years 1946 and 1947 in the respective amounts of $10,799.76 and $1,105.69.
The sole question presented is whether the income realized by petitioner from the sale of real property in the taxable years involved is taxable as ordinary income or capital gain.
Nearly all the facts are stipulated and are found accordingly.
Findings of Fact
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