OPINION
STERRETT, Judge:
The respondent determined deficiencies in the Federal income tax of the petitioner for the taxable years 1964, 1965, and 1966 in the amounts of $6,413.63, $7,178.99, and $1,623.46, respectively. Due to concessions of the parties the sole issue remaining for decision is whether certain payments under a document styled "Sand and Gravel Deed" are long-term capital gain or, as the respondent contends, ordinary income subject to...
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