Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, by means of a statutory notice of deficiency, determined a Federal income tax deficiency for petitioners' 1986 taxable year in the amount of $120,348.75. After concessions, the issue remaining for our consideration is whether petitioners are entitled to capital gain or ordinary income treatment on gain realized from the sale of a parcel of land.
Findings of Fact
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