Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined an income tax deficiency of $8,317.57 against petitioner for the year 1943. The question is whether or not petitioner received in 1943 as income from an invention by him a payment of $10,000, and by reason thereof received in the taxable year 80 per cent of the aggregate income from the said invention during the taxable year, the year preceding and the year following so as to...
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