Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined deficiencies in income tax for the calendar years 1955, 1956, and 1957 in the amounts of $69,271.62, $80,858.45, and $70,046.91, respectively, plus an addition to tax under section 6654, I. R. C. 1954, for 1955 of $1,089.84.
The pleadings present a number of issues. Petitioners have agreed to all the adjustments except those relating to whether the gain from three tracts...
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