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SYMONDS v. COMMISSIONER

Docket Nos. 21529, 26473, 21528, 26472.

10 T.C.M. 712 (1951)

Robert C. Symonds v. Commissioner. Gladys E. Symonds v. Commissioner.

United States Tax Court.

Entered August 15, 1951.

Attorney(s) appearing for the Case

Alva C. Baird, Esq., and William A. Cruikshank, Jr., Esq., for the petitioners. William P. Flynn, Jr., Esq., and Robert H. Kinderman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income tax for the years 1945, 1946, and 1947 of $4,014.17, $8,025.35, and $929.90, respectively, against petitioner Robert C. Symonds, and of $3,939.16, $7,954.10, and $806.40, respectively, against petitioner Gladys E. Symonds. The sole issue is whether capital gain treatment is to be accorded to profits on real estate sales by petitioners during the taxable years...

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