OPINION.
MURDOCK, Judge:
The Commissioner determined an income tax deficiency of $1,180.31 against Isadore Golonsky and one of $901.40 against Frank Gold, for 1944. The only issue is whether the Commissioner erred in holding that $3,750, the amount received by each petitioner from Sansom Realty Company, was taxable to him as ordinary income instead of as a long term capital gain. The facts have been stipulated.
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