Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined a deficiency in the income tax of petitioners for the calendar year 1959 in the amount of $2,150.97.
The sole issue is whether certain amounts received by petitioner John C. Sims, Jr. from the Sperry Rand Corporation in 1959 pursuant to a settlement agreement, as amended, are taxable as ordinary income or capital gain.
Findings of Fact
Petitioners are husband...
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