ARNOLD v. COMMISSIONER

Docket No. 36427.

12 T.C.M. 280 (1953)

N. J. Arnold v. Commissioner.

United States Tax Court.

March 17, 1953.


Attorney(s) appearing for the Case

William B. Murray, Esq., 525 Failing Building, Portland, Ore., for the petitioner. John H. Welch, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

This proceeding involves a deficiency of $9,568.27 in income tax for 1945. The issue is whether gain realized by petitioner from sales of lots in 1945 is taxable to him in that year, and, if so, whether the amount constitutes ordinary income or capital gain.

Findings of Fact

The facts set forth in a stipulation are so found.

The petitioner, an individual, residing in Salem...

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