Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1962 and 1963 in the respective amounts of $6,314.43 and $4,453.93.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision whether certain tracts of land located in Westchester Estates were held by petitioner primarily for sale to customers in the...
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