Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in the income tax of petitioners in the amounts of $13,089.28 for the year 1953 and $12,380.81 for the year 1954.
The sole remaining issue for decision is whether certain amounts, which petitioners received from a contractor for fill dirt used in the construction of a highway, constituted proceeds from the sale of capital assets, or ordinary income.
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