TIETJENS, Judge:
The Commissioner determined a deficiency in income tax for the year 1954 in the amount of $13,000.
The only issue is whether the amount of $50,000 received by petitioner in 1954 pursuant to the terms of an agreement whereby it granted an extension of a license with option to purchase to its licensee, was includible in its income for that year.
FINDINGS OF FACT.
Some of the facts are stipulated, are so found, and are...
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