MEMORANDUM OPINION
RAUM, Judge:
The Commissioner determined deficiencies in petitioner's Federal income taxes totaling $28,802 in 1986 and $28,961 in 1989. At issue is whether a loss from the sale of real estate should be characterized as ordinary or capital. The parties agree that the resolution of this issue controls the treatment of the loss carried back to 1986.
Petitioner, Christine C. Deignan, resided in Davenport, Iowa, at the time the petition...
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