Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax of petitioners for the calendar year 1950 in the amount of $968.96.
The sole issue is whether the sum of $9,200 received by petitioners in 1950 from Arthur Caplan and Associates should be taxed as ordinary income or as long-term capital gain.
Findings of Fact
Petitioners are husband and wife who, in 1950, resided in Salt Lake City, Utah. Their joint...
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