Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax of $66,515.76 for 1944 and $171,291.71 for 1945. The issues for decision are: (1) Whether three hotels were held primarily for sale to customers in the ordinary course of the petitioner's business so that the gain was taxable as ordinary income rather than as long-term capital gain; (2) whether there was a partnership for tax purposes, including the petitioner and six...
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