The Commissioner determined a deficiency of $52,496.94 in income tax for 1944. The only issue for decision is whether $66,150.56 received by the petitioner in 1944 represented ordinary income or whether it represented a long term capital gain.
FINDINGS OF FACT.
The petitioner filed his individual income tax return for 1944 with the collector of internal revenue for the district of Michigan. He kept his records and filed his returns on a cash receipts and...
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