ATKINS, Judge:
The respondent determined deficiencies in income tax of the petitioners for the years 1951, 1952, and 1953 in the amounts of $4,556.35, $1,081.79, and $2,054.36, respectively. The single issue framed by the pleadings is whether payments received by the petitioners in the above years from the transfer of patent rights constituted long-term capital gains as they were reported in the income tax returns or whether such payments were royalties taxable...
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