Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency in income tax of $583.46 for the year 1937, predicated on his holding that "the amount of $7,261.30 received by you [petitioners] in the year 1937 as a result of the judgment in a civil action handed down by the Supreme Court of Pennsylvania against John Jacobs, is taxable as ordinary income."
The facts were all stipulated and the stipulation is hereby adopted as the facts...
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