Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined a deficiency in petitioners' federal income tax for the taxable year 1968 in the amount of $46,633.57. The issue in controversy is whether a sale of 133.111 acres of land to Federated Department Stores, Inc., in February, 1968, by a joint venture known as Meadow Brook Farm, in which petitioner William B. Dean held a one-third interest, resulted in the realization of ordinary...
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