Memorandum Opinion
OPPER, Judge:
This proceeding seeks a redetermination of deficiencies of petitioners' income tax for the years 1938, 1939, and 1940 in the sums of $167.54, $267.07, and $141.59, respectively.
Petitioners concede an adjustment of $556.50 made in 1939 income relating to gain from the sale of property. The remaining question is the taxability to petitioners of the income from properties subject to an agreement between one of the petitioners...
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