Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined deficiencies in the income taxes of the petitioners for the taxable calendar years 1957 and 1958 in the amounts of $9,836.51 and $19,447.15, respectively. The sole issue for decision is whether the gains from sales by petitioner of vacant lots in a subdivision created by him, are taxable as ordinary income or as long-term capital gain.
Decision of the issue depends upon...
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