Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in the income tax of the petitioner for the calendar years 1963 and 1964 in the respective amounts of $57,985.15 and $7,032.52. At the hearing of this case the petitioner conceded the correctness of the respondent's determination of deficiency for 1964. The only issue remaining for our decision relates to the determination by the respondent that real estate sold by the petitioner in 1963...
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