OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $22,182.33 in the income tax of the petitioners for 1948. The questions for decision are (1) whether the entire amount received by the husband in 1948 as compensation for personal services rendered by him over a period extending from 1936 into 1945 should be treated as taxable to him in determining the taxes which would have resulted from attributing it ratably to the years when...
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