STERRETT, Judge:
Respondent determined deficiencies in income tax for the calendar years 1961, 1962, and 1963 in the amounts of $11,206.42, $13,353.13, and $20,613.92, respectively.
The only issue for decision is whether certain income is taxable as ordinary income or as long-term capital gain.
FINDINGS OF FACT
Most of the facts have been stipulated. The stipulation and the exhibits attached thereto are incorporated herein by reference...
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