Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in the petitioners' income tax for the calendar year 1963 in the amount of $1,189.77.
The only issue in the case is whether the payments received by petitioner for the relinquishment of his leasehold constitute capital gain or are to be treated as ordinary income pursuant to section 1239 of the Internal Revenue Code of 1954.
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