Memorandum Findings of Fact and Opinion
These consolidated proceedings involve deficiencies in income tax for the calendar year 1944 of $43,406.44 for Ed Krist (hereinafter referred to as the petitioner) and $43,406.46 for Florine Krist, his wife.
The issues to be determined are: (1) whether petitioner sold his interest in a partnership and is entitled to accord capitalgains treatment to the profit therefrom; and (2) whether installment obligations owned...
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