The respondent determined a deficiency in petitioner's income tax for the taxable year 1954 in the amount of $283,660.86.
The only question remaining for decision is whether $409,336.34 received by the petitioner during 1954 pursuant to the terms of an agreement with Universal Pictures Company, Inc., represents capital gain, as contended by her, or is ordinary income, as determined by the Commissioner. The amount originally in issue has been substantially reduced...
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