Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner challenges respondent's determination of deficiencies in income tax for 1944, 1945 and 1946 of $4,103.45, $10,297.31 and $43,583.86, and a delinquency penalty under section 291(a), Internal Revenue Code, for 1944 of $488.95. Certain adjustments are not contested. The sole issue is whether petitioner is entitled to capital gain treatment on profits from sales of real estate.
Findings...
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