OPINION.
PIERCE, Judge:
The respondent determined a deficiency in the petitioners' income tax for the year 1956 in the amount of $18,843.76.
The sole issue for decision is whether amounts received in the taxable year 1956 by the principal petitioner from his controlled corporation, pursuant to a contract whereby he sold and assigned to such corporation all rights to a patent developed by him, are taxable to said petitioner-inventor as ordinary...
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