Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in income taxes of the petitioner for the years 1955 and 1956 in the respective amounts of $1,527.47 and $34,376.95.
The single issue for decision is whether gains realized by petitioner in 1955 and 1956 from the sale of certain building lots are taxable as gains from the sale of capital assets or as ordinary income from the sale of property held by petitioner...
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