Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for 1975 and 1976 in the amounts of $4,577.95 and $4,736.17, respectively. Due to concessions by petitioners, the issues for decision are (1) whether petitioners made substantial improvements that substantially enhanced the value of certain subdivided real property so as to foreclose special capital gains treatment under section 1237...
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