The respondent has determined a deficiency of $1,282.40 in petitioner's income tax for 1947. The only question in issue is whether the entire gain realized by the petitioner on the sale of a farm is taxable as capital gains or whether a portion thereof was from the sale of a growing crop of wheat and taxable as ordinary income.
FINDINGS OF FACT.
The following facts have been stipulated:
1. Petitioner is an individual, engaged in the business of farming...
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