Memorandum Opinion
JOHNSON, Judge:
The Commissioner determined deficiencies in petitioners' income tax for 1944 as follows: Arthur N. Trembley, $464.05; Adele Trembley Wilson, $263.96; Corinne T. Barnes, $277.46.
The sole question presented is whether conveyances by petitioner were sales, and profits therefrom taxable as long term capital gains, as they claim, or whether, as respondent determined, that same were mineral leases and amounts received...
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