ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1957 in the amount of $44,864.77.
The parties having reached agreement as to certain issues, the issue remaining for decision is whether the sum of $89,000 paid to the petitioner Ralph Bellamy in 1957 was proceeds from the sale by him of property which was a capital asset, resulting in the receipt of long-term capital gain as contended by him, or is taxable as ordinary...
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