Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined a deficiency in the petitioners' income tax for the calendar year 1954 in the amount of $521.76. The only issue is whether the gain realized from the sales of certain real estate in 1954 was ordinary income or capital gain.
Findings of Fact
Some of the facts are stipulated and are hereby found as stipulated.
Adolph and Edith Dantagnan are husband and...
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