Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax against the petitioners for the taxable year 1951 in the amount of $1,623.37.
The sole issue in this case is whether gains realized from the sale of two lots in which the petitioners had an interest should be taxed as long-term capital gains or as ordinary income.
Findings of Fact
Some of the facts have been stipulated and they are found accordingly...
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