Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in income taxes determined against Raymond Saltzman for the years 1946 and 1947 in the respective amounts of $4,493.77 and $3,321.39.
The sole issue to be decided is whether the gains realized by petitioner on the sale of various real properties during the years 1944 to 1947, inclusive, are taxable as ordinary income or as capital gains. Certain sales made on the installment basis...
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