MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $70,132 for 1993 and $63,075 for 1994.
After concessions, the sole issue for decision is whether petitioner's losses from the sale of residential lots of $207,850 in 1993 and $166,599 in 1994 were capital losses, as respondent contends, or ordinary losses, as petitioner contends. To prevail, petitioner must show that she...
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