The respondent has determined a deficiency in income tax in the amount of $14,288.58 for the taxable (calendar) year ended December 31, 1952. The deficiency is due to one adjustment—the determination that the gain of $44,100 on the sale of real property by petitioner to a corporation, whose stock was solely owned by the petitioners and their son, was ordinary income rather than long-term capital gain as reported by the petitioners.
Petitioners, by an appropriate...
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