The respondent determined deficiencies in income tax against the petitioner for the years 1950, 1951, and 1952 of $11,224.33, $69,677.64, and $80,219.88. The only question for decision is whether gains realized on the sale of real estate during the years herein are taxable as long-term capital gains, or as ordinary income. One issue involving the disallowance of a claimed interest deduction has been conceded by petitioner.
FINDINGS OF FACT.
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