Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $8,672.24 in income tax of the petitioners for 1958. The sole issue for decision is whether $26,258.39 received by Malloy in 1958 from R&R Insurance Service, Inc., was a long-term capital gain, as reported, or was ordinary income, as determined by the Commissioner.
Findings of Fact
The petitioners, husband and wife, filed their cash basis joint Federal income...
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