The Commissioner determined a deficiency of $10,303.52 in the income tax of the petitioner for the calendar year 1944. The only issue for decision is whether $37,500 received by the petitioner during 1944 was taxable as compensation for personal services for a period of 36 calendar months or more, which the petitioner was entitled to report in accordance with section 107 (a) of the Internal Revenue Code.
FINDINGS OF FACT.
The petitioner filed his individual...
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