The Commissioner determined a deficiency of $7,086.50 in petitioner's income and victory tax for 1943 in part by treating payments received in 1942 and 1943 from the assignee of mining claims under a lease with option to purchase as royalties and, hence, ordinary income. Petitioner contends that such payments were derived from the sale of the claims and are taxable as capital gains. The proceeding was submitted upon a stipulation, which we incorporate by reference as findings...
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