Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income taxes for the calendar years 1938, 1939, 1940 and 1941 in the respective amounts of $721.69, $1,215.03, $1,575.44 and $2,932.09. The issue with respect to all years involved is whether amounts received by petitioner resulting from the disposition of patents or inventions are capital gains or ordinary income.
Findings of Fact
Petitioner is an...
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