Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $6,691.23 and $6,945.57 in the income tax liabilities of the petitioners, C. E. King, hereinafter called petitioner, and Juanita M. King, respectively, for the year 1946.
The only issue is whether or not a gain realized on the sale of 49 houses in the taxable year is taxable as ordinary income or as capital gain.
The case is submitted upon the pleadings and the oral...
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