Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined deficiencies in the income tax of petitioners for the taxable years 1954 and 1955 in the respective amounts of $8,643.74 and $1,764.72.
The issues before us to be decided are (1) whether respondent has erred in treating gains of petitioners from the sale of real estate as ordinary income and (2) whether petitioners are entitled to deductions for business entertainment...
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