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HAMME v. COMMISSIONER

Docket Nos. 36037, 36038.

12 T.C.M. 335 (1953)

Joseph Hamme v. Commissioner. R. H. Hamme v. Commissioner.

United States Tax Court.

March 30, 1953.

Attorney(s) appearing for the Case

Stanley Worth, Esq. c/o Blair, Korner, Doyle & Appel, 404 Transportation Building, Washington, D. C., and Edward S. Smith, Esq., for the petitioners. E. M. Woolf, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax as follows:

  Year          Joseph Hamme   R. H. Hamme

  1944 .......  $   856.96     $ 1,014.06
  1945 .......      555.20         727.87
  1946 .......    1,012.54       1,267.41
  1947 .......   11,034.16      10,680.17

The issues for decision are whether amounts received in each year under contract dated March 4, 1944, were royalties taxable...

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