OPINION
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1964 in the amount of $2,153.59.
The only issue for decision is whether an amount received by petitioners as profit from the construction and sale of 18 condominium units pursuant to an agreement entitled "Joint Venture Agreement," is ordinary income or capital gain.
All of the facts have been stipulated and are found accordingly...
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