OPINION
TIETJENS, Judge:
The Commissioner determined deficiencies in petitioners' income taxes of $1,310.14, $1,842.59, and $477.82, respectively, for 1963, 1964, and 1965.
We must decide whether petitioners are entitled to have the gains from their sales of real estate lots during each of these years taxed at capital gain rates rather than at ordinary-income rates.
All of the facts have been...
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