COLLINS v. COMMISSIONER

Docket No. 4784-70.

31 T.C.M. 835 (1972)

T.C. Memo. 1972-170

Frederic A. Collins and Gloria R. Collins v. Commissioner.

United States Tax Court.

Filed August 9, 1972.


Attorney(s) appearing for the Case

Frederic A. Collins, pro se, 6 Pierrepont St., Brooklyn, N.Y. Barry D. Gordon, for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

In this proceeding, the Commissioner determined a deficiency in Federal income tax against the petitioners for the year 1966 in the amount of $4,015.91. Concessions having been made, the sole question for decision is whether $18,700 reported by the petitioners as long-term capital gain should properly have been included as ordinary income in 1966.

Findings of Fact

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