Memorandum Findings of Fact and Opinion
PIERCE, Judge:
For the calendar years 1949 and 1950, and for the short taxable period January 1 to March 31, 1951, the respondent determined deficiencies in the income taxes of the petitioners in the respective amounts of $1,163.48, $9,171.89, and $674.89. The sole issue for decision is whether the gains, which petitioner Charles E. Hall realized during the taxable periods from the sale of certain improved residential...
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