Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency in the income tax of petitioner for its taxable year 1957 has been determined by respondent in the amount of $13,105.48. The sole issue presented by the pleadings is the amount of capital gain realized by petitioner in 1953 upon its sale of real property. Disposition of this issue will be determinative of the amount of petitioner's net operating loss and net long-term capital gain for 1957...
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