This proceeding involves deficiencies in income tax for the years 1951 and 1952 in the respective amounts of $12,343.28 and $9,560.42.
The sole issue is whether amounts which petitioner, Hans Jordan, received during the years in issue were the proceeds from the sale of a patent and, therefore, taxable as long-term capital gains under the provisions of section 117 (q) of the 1939 Code.
This case was first submitted to the Court sitting at Los Angeles, California...
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