Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves income tax deficiencies for the years 1939, 1940 and 1941 in the respective amounts of $3,170.20, $9,476.94 and $9,799.78. The sole question presented is whether petitioner realized capital gain or ordinary gain from an installment sale made on October 3, 1939.
Petitioner is an individual residing in Doylestown, Ohio. His tax returns for the years in question, computed...
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