DAWSON, Judge:
Respondent determined income tax deficiencies against petitioners for the years 1961, 1962, and 1963 in the amounts of $1,271.53, $2,957.67, and $2,409.36, respectively.
The issues for decision are (1) whether the petitioners' developmental activities on real estate owned by them constituted "substantial improvement that substantially enhanced" the value of the property so as to foreclose special capital gains treatment under section...
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