Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Year Deficiency 1980 ........................ $ 2,705.00 1981 ........................ 50,022.75 1982 ........................ 3,871.00
After various concessions by respondent, the issue for decision is whether, for capital gains tax purposes...
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