RYMER v. COMMISSIONER

Docket No. 16750-80.

52 T.C.M. 964 (1986)

T.C. Memo. 1986-534

C. Edwin Rymer v. Commissioner.

United States Tax Court.

Filed November 4, 1986.


Attorney(s) appearing for the Case

C. Edwin Rymer, pro se. Ben G. Reeves, for the respondent.


Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioner for 1976 in the amount of $6,177.43. After concessions by both parties, the issues for decision1 are as follows:

(1) Whether petitioner held real property primarily for sale to customers in the ordinary course of his trade or business, so that the gain from the sale of this property...

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