Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined deficiencies in petitioner's federal income tax for the fiscal years ended August 31, 1969 and August 31, 1970 in the amounts of $51,541.25 and $32,773.68, respectively. The sole issue in controversy is whether the gain realized from the sale of land held by the petitioner should be characterized as ordinary income or capital gain. To settle this issue we must determine whether...
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