Memorandum Findings of Fact and Opinion
DAWSON, Judge:
In these consolidated proceedings the respondent determined deficiencies in the income taxes of petitioners for the years 1959 and 1960 in the amounts of $7,749.63 and $15,773.90, respectively.
These deficiencies arise mainly from respondent's determination that petitioners were not entitled to treat certain amounts received in 1959 and 1960 as proceeds from the sale of capital assets taxable...
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