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TELINDE v. COMMISSIONER

Docket No. 29712.

18 T.C. 91 (1952)

RICHARD W. TELINDE AND CATHARINE L. TELINDE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 18, 1952.

Attorney(s) appearing for the Case

Joshua W. Miles, Esq., and D. Sylvan Friedman, Esq., for the petitioners.

Stephen P. Cadden, Esq., for the respondent.

Petitioners challenge respondent's determination of deficiencies in income tax for the years 1947 and 1948, of $8,756.87 and $935.42, respectively, all of which is in dispute. The issue in controversy is whether payments received in connection with the publication of a book were royalties, and in the alternative, if the amounts constituted proceeds from the sale of a capital asset, whether the asset was held for more than 6 months...

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