Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the years 1951 and 1952 in the amounts of $668.94 and $793.36, respectively. The principal question presented is whether certain payments received by petitioner, Monie S. Hudson, constituted royalties, taxable as ordinary income, or proceeds from the sale of a capital asset, taxable as long-term capital gain. A subsidiary issue relating to the...
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