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STOUT v. COMMISSIONER

Docket No. 15548.

8 T.C.M. 988 (1949)

William B. Stout v. Commissioner.

United States Tax Court.

Entered November 2, 1949.

Attorney(s) appearing for the Case

R. M. O'Hara, Esq., and Harry A. Smith, C. P. A., for the petitioner. R. E. Maiden, Jr., Esq., and E. A. Tonjes, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

The Commissioner determined a deficiency of $16,039.75 in petitioner's income tax for the fiscal year ended November 30, 1944. Petitioner received $35,000 payable as "royalties" under a contract whereby he caused patents and other assets to be transferred to a corporation which employed him as a research director. He charges error in the Commissioner's determination that the $35,000 is taxable as ordinary...

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