Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in the Federal income tax of the petitioner for the year ended December 31, 1966, in the amount of $3,498.47. Certain issues have been settled by concession of the parties. The remaining issue is whether gains from sales of real property recognized in 1966 qualify for capital gains treatment under section 1201, I. R. C. 1954. If our conclusion is in the affirmative...
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