Memorandum Findings of Fact and Opinion
QUEALY, Judge:
In this proceeding, the Commissioner determined a deficiency in Federal income tax against the petitioners for the year 1966 in the amount of $4,015.91. Concessions having been made, the sole question for decision is whether $18,700 reported by the petitioners as long-term capital gain should properly have been included as ordinary income in 1966.
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