Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency in income tax against petitioners for the calendar year 1955 in the amount of $3,705.16.
The issues presented for decision are:
1. Whether gain realized by petitioners from the sale of their interest in a certain motel represents gain from the sale of a capital asset; or whether it constitutes ordinary income from the sale of property held primarily...
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