Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in income tax in the amount of $59,395.20 for the taxable year 1955.
The issue for decision is whether, as claimed by the petitioner, she realized a long-term capital gain of $100,000 upon the sale of assets of a business or whether, as determined by the respondent, she derived ordinary income in that amount. Other allegations of error have been abandoned...
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