The respondent determined a deficiency in the petitioners' income tax liability for the taxable year ended December 31, 1951, in the amount of $24,006.76.
The question presented is whether payments received by the petitioner Thornton G. Graham, under an agreement purporting to convey all of his interest in certain patent rights, are taxable as ordinary income or as long-term capital gain.
FINDINGS OF FACT.
The facts are stipulated and are found as...
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