Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in income tax for the calendar year 1952 in the amount of $950.84. The primary issue is whether the respondent erred in determining that lots sold by the petitioner in that year constituted property held primarily for sale to csutomers in the ordinary course of trade or business and that consequently the gain realized was ordinary income. A secondary issue is whether...
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