Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies have been determined in the income tax of petitioner for the taxable years 1958 and 1959 in the respective amounts of $7,586.37 and $15,568.91. By an amendment to its petition, petitioner claims an overpayment of its income tax for each year.
The primary issue to be determined is whether respondent has erred in treating petitioner's receipts from sales of lots in each year on an...
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