Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in income tax of $1,433.87 and $2,473.45 against the petitioners for the years 1958 and 1959.
The only question for decision is whether profits realized upon the sale of lots during the taxable years represented capital gain or ordinary income.
Findings of Fact
Some of the facts have been stipulated and are found as stipulated.
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