This proceeding involves deficiencies in corporate income and excess profits taxes for the fiscal year ending September 30, 1946, in the amounts of $10,669.10 and $51,878.16, respectively.
The only question for our determination is whether the amount of $241,973.34 received by petitioner under a settlement agreement is taxable as ordinary income or as a long term capital gain.
The case was submitted on a stipulation of facts and oral and documentary evidence...
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