Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1971 and 1972 in the respective amounts of $1,145.24 and $2,119.31. The only issue presented for our decision is whether improved lots sold by Margaret R. Ackermann during the years in issue were properties held primarily for sale to customers in the ordinary course of trade or business at the time of sale.
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