KESSLER v. COMMISSIONER

Docket No. 9478-78.

44 T.C.M. 624 (1982)

T.C. Memo. 1982-432

Stephen F. Kessler and Anna Merle Kessler v. Commissioner.

United States Tax Court.

Filed July 28, 1982.


Attorney(s) appearing for the Case

Stephen F. Kessler, pro se. Theodore F. Brill and Ivan A. Gomez, for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:*

Respondent determined an $11,805.38 deficiency in petitioners' 1974 income tax. The sole issue for decision is whether petitioners realized ordinary income or capital gain on receipt of five percent of the profits from the sale of certain real property.

Findings of Fact

Some of the facts have been stipulated and are found accordingly. The stipulations...

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