Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $10,910.83 in income tax of the petitioner for 1947. The issue for decision is whether $31,250, which the petitioner received in 1947 as the result of an out-of-court settlement of a law suit, is ordinary income, capital gain, or a return of capital.
Findings of Fact
The petitioner filed his individual income tax return for 1947 with the collector of internal revenue...
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