Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding was brought for a redetermination of a deficiency in income tax of $6,121.05 for the year 1938.
The amount of the loss from the disposition by petitioner of certain real estate having been stipulated, the only question is whether it is free from the capital loss limitations because involving "property held by the taxpayer primarily for sale to customers in the ordinary course of...
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