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WHEELER v. COMMISSIONER

Docket No. 5571-70.

58 T.C. 459 (1972)

ELLIS D. WHEELER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 14, 1972.

Attorney(s) appearing for the Case

Ellis D. Wheeler, pro se.

Daniel A. Taylor, Jr., for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for 1967 in the amount of $3,711.83 and an addition to his tax under section 6653(a)1 in the amount of $185.59. Petitioner has conceded certain adjustments, and the only issues remaining for decision are as follows:

(1) Whether petitioner realized income, taxable in part as long-term capital gain and in part as ordinary income, upon...

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