Memorandum Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $7,046.44 in petitioner's income tax for the taxable year ended March 31, 1967. The sole issue is whether gain realized by petitioner in the amount of $33,519.63, from a payment it received in cancellation of a land lease, constituted ordinary income or long-term capital gain. The facts have been stipulated.
Modiano-Schneider, Inc. ("petitioner", "Modiano-Schneider" or "the...
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