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JOHNSON v. COMMISSIONER

Docket No. 1349-75.

35 T.C.M. 402 (1976)

T.C. Memo. 1976-95

Gilbert H. and Juanita W. Johnson v. Commissioner.

United States Tax Court.

Filed March 25, 1976.

Attorney(s) appearing for the Case

Gilbert H. Johnson, pro se, 100 Evergreen Hill Rd., Fairfield, Conn. Daniel P. Ehrenreich, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in the amounts of $2,756.05 and $100.42 in petitioners' Federal income tax for 1971 and 1972, respectively.

The only issue to be decided is whether petitioners realized ordinary income or capital gains from the sale of certain items of machinery during the years in issue. The answer turns on whether the...

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