Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency of $5,515.45 in petitioners' Federal income tax for 1971. The sole issue in controversy is whether the gain realized from the sale of certain contingent mineral interests should be characterized as ordinary income or capital gain. The answer depends upon whether petitioners held the property as an investment or primarily for sale to customers in the ordinary course...
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