Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax in the amounts of $2,320 and $7,396 for the taxable years 1974 and 1975, respectively. The issue before the Court is whether petitioners are entitled to capital gains treatment for land that they have held for several years, when they later sub-divide the land into 16 lots, construct 16 single-family homes thereon, and sell these improved...
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