Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in income tax of petitioners for the year 1955 of $13,034.81. The deficiency is due to two adjustments made to the net income as reported on the joint return filed by petitioners. The first adjustment is not in issue. The second adjustment was to determine that gain resulting from the sale by petitioner J. Kirby Reppell of certain real property which he owned was ordinary income...
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