United States Tax Court.
Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency of $26,801.09 in the income tax liability of the petitioner for the calendar year 1946.
The issue is whether or not a gain realized on the sale of 20 houses in the taxable year is taxable as ordinary income or as long-term capital gain. Petitioner's 1946 Federal income tax return reported the
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