Memorandum Findings of Fact and Opinion
KERN, Judge:
In Docket No. 102243 respondent determined a deficiency in the income tax liability of petitioner, Edward H. Heller for the year ended December 31, 1936 in the sum of $5,449.15. In the petition filed in this docket number petitioner alleges certain errors in such determination as follows:
(a) The Commissioner of Internal Revenue erred in determining that the profits from the sale of certain real...
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