Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the income tax liability of petitioners for the taxable years 1967 and 1968 in the respective amounts of $1,814.93 and $2,118.81. The issue is whether petitioners realized ordinary income in taxable years 1967 and 1968 on amounts they received pursuant to an agreement with the Pacific Sand and Gravel Co. for removal of sand and gravel from their real property.
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