FAY, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1971 in the amount of $18,951.
Due to concessions, the sole issue remaining is whether the gain realized by petitioner on the sale of a portion of its contractual right to receive certain water was capital gain or ordinary income.
FINDINGS OF FACT
Certain facts were stipulated and are so found.
Petitioner Buena Vista Farms...
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