Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax of petitioner for the fiscal year ended February 28, 1947, in the amount of $13,631.06. The only issue presented is whether the gain realized upon the sale of certain properties was taxable as ordinary income or, under the provisions of section 117 (j), Internal Revenue Code, as capital gain.
Findings of Fact
The facts stipulated are found accordingly....
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