Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax in the amounts of $33,969.51 and $40,527.97 for the years 1953 and 1954, respectively. The issue for decision is whether gains which resulted from the sale of certain property by the petitioner, a part of which was received in the taxable year 1953 and a part in the taxable year 1954, are taxable to petitioner as long-term capital gains or as short...
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