Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined a deficiency in income tax due from the petitioners for the taxable year 1974 in the amount of $10,131.00. The sole question for decision is whether the gain of $40,000.00 realized in connection with the purchase and resale of certain property is taxable as ordinary income or should be treated as a long-term capital gain.
Findings of Fact
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