These proceedings, consolidated for hearing, are for the redetermination of deficiencies in income tax for 1939 of the petitioners Jack Rosenzweig and Henry Rose in the amounts of $2,182.60 and $11,098.55, respectively. The points in issue are:
(1) Whether Henry Rose is liable to income tax upon the full amount of $58,500 received as the net proceeds from the compromise of an infringement suit or upon only $33,500, which was the amount received and enjoyed by him...
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