OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $27,582.20 in income tax of the petitioners for 1952. The facts have been submitted by stipulations which are adopted as the findings of fact. The question is whether a gain realized by the petitioner is taxable as ordinary income under section 117(m).
The petitioners are husband and wife. They filed a joint return for 1952 on...
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