Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax for the year 1946 in the amount of $3,179.87. The only question presented is whether the gain derived by the petitioner from the sale of six duplex dwelling units is to be taxed as capital gain or ordinary income.
Findings of Fact
The facts stipulated are found accordingly.
John P. Dougherty, the petitioner, is a resident of Canton, Ohio, and filed...
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