This proceeding involves an income tax deficiency in the amount of $50,740.43 for the calendar year 1947.
Petitioner assigns error in the respondent's determination: (1) that the amount of $100,220.44 received in the taxable year constituted ordinary income derived from royalties rather than a long term capital gain derived from a sale of patents, and (2) that the amount of $499.50 paid in taxable year as premiums on life insurance payable to petitioner's divorced...
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