THOMAS v. COMMISSIONER

Docket No. 52435.

28 T.C. 1 (1957)

ROBERT THOMAS AND SUSAN B. THOMAS, HUSBAND AND WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 4, 1957.


Attorney(s) appearing for the Case

E. Snow Martin, Esq., and John J. Trenam, Esq., for the petitioners.

Hugh G. Isley, Jr., Esq., for the respondent.


The respondent determined a deficiency in income tax against the petitioners for the year 1950 in the amount of $27,740.52. The question presented is whether the gain realized upon the sale of certain properties in 1950 was ordinary income or capital gain.

FINDINGS OF FACT.

Some of the facts have been stipulated and are found as stipulated.

The petitioners are husband and wife, and reside in Tampa, Florida. They filed a joint income tax return for...

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