Pool

' In this review of the determination of income tax deficiencies against the taxpayers for the calendar years 1946, *235 1947 and 1948, six consolidated cases are involved. The decisions of the Tax Court were entered on August 20, 1956. The deficiencies were as follows:

For the years 1946-1947 Edward Pool 5,697.

86.828.

For the years 1946-1947 Lottie Pool 5,697.

86.828.

For the year 1948 Edward and Lottie Pool 18,651.

For the years 1946-1947 William K. Murphy 3,410.

98.401.

For the years 1946-1947 Edna Murphy 3,410.

98.401.

For the year 1948 William K. and Edna Murphy 17,349.

It is the contention of the taxpayers that the decisions are clearly erroneous and should be set aside. 1 It is also argued that these are cases in which the Tax Court misapplied the law to proved facts. 2 In the main, it is asserted that the Tax Court erred in treating the income derived from the sales of two sets of duplexes owned by the petitioners as ordinary income under Section 22 of the Internal Revenue Code of 1939. 3 To the contrary, it is insisted that the sales should have been treated as the liquidation of an investment and the income subjected to the tax called for…