Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1940 in the amount of $8,785.99. The two issues relate to the Commissioner's action in including in petitioner's taxable income 50% of the amount received by petitioner on account of the sale of certain patents but paid by him to his wife pursuant to an agreement, and reported by her for taxation; and in determining that the proceeds...
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