HOPKINS v. COMMISSIONER

Docket No. 9931.

15 T.C. 160 (1950)

JOHN RANDOLPH HOPKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 29, 1950.


Attorney(s) appearing for the Case

Benjamin Mahler, Esq., for the petitioner.

Henry C. Clark, Esq., for the respondent.


ARUNDELL, Judge:

The respondent has determined deficiencies against petitioner in the amount of $25,121.39 for the calendar year 1939, $22,275.01 for the calendar year 1940, and $38,737.53 for the calendar year 1941.

The petitioner assigns errors in the respondent's determination:

(1) That certain annual sums received by petitioner from Lambert Pharmacal Co. constituted ordinary income rather than (a) capital gains, or (b) tax-free amortization...

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