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SHUMLIN v. COMMISSIONER

Docket No. 23368.

16 T.C. 407 (1951)

HERMAN SHUMLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 20, 1951.

Attorney(s) appearing for the Case

Jacob Rabkin, Esq., for the petitioner.

Sheldon V. Ekman, Esq., for the respondent.

Petitioner assails respondent's determination of a deficiency of $11,548.64 in income and victory tax for 1943. The year 1942 is involved under the Current Tax Payment Act of 1943. One adjustment is not contested and concessions of the parties have disposed of one issue. The remaining issues are whether certain income, arising out of a transaction involving motion picture rights, constituted ordinary income or capital gain, and whether...

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