OPINION
RAUM, Judge:
Respondent determined a deficiency in the income tax of petitioner in the amount of $168,424.36 for the calendar year 1959. All of the facts have been stipulated.
The sole issue is whether the respondent erred in determining that the entire amount of damages received by petitioner in a patent infringement suit was taxable as ordinary income.
Petitioner, an Ohio corporation with principal office in Mainville, Ohio...
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