DAWSON, Judge:
Respondent determined a deficiency in petitioner's income tax for the taxable year ended April 28, 1962, in the amount of $122,630.31. This deficiency arose mainly from respondent's determination that the gain from the sale of certain television films should be treated as ordinary income rather than capital gain and the disallowance of a depreciation deduction taken in the year the films were sold.
Several issues have been settled by stipulation...
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