Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency in the income tax liability of petitioner and affiliated companies totaling $15,734.84 for the year ended December 31, 1946. A depreciation adjustment is not contested. The sole issue is whether petitioner properly reported a profit realized in 1946 as a long-term capital gain, rather than as ordinary income.
Findings of Fact
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