EDWARDS v. COMMISSIONER

Docket Nos. 40059, 40060.

12 T.C.M. 1045 (1953)

P. S. Edwards and Helen R. Edwards v. Commissioner. P. S. Edwards v. Commissioner.

United States Tax Court.

Entered September 10, 1953.


Attorney(s) appearing for the Case

Campbell Napier, Esq., 830 West Peachtree Street Building, Atlanta, Ga., for the petitioners. D. Z. Cauble, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The respondent determined deficiencies in income tax of $9,053.87 for 1947 and $648.30 for 1948.

Two questions are presented for decision: (1) Whether the gain on the sale of certain real estate constituted ordinary income or capital gain; and (2) whether the petitioners realized taxable income from a transaction in which another member of a joint venture of which the petitioners also were...

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