Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined a deficiency of $21,333.83 in the Federal income tax of Sapphire Lands, Inc., for the year ended November 30, 1967, and a deficiency of $584.35 in the Federal income tax of Garnet Lands, Inc., for the year ended November 30, 1967. The only issue for decision is whether during 1967 the petitioners held certain land primarily for...
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