Memorandum Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax against the petitioners for the year 1962 in the amount of $1,567.93 and a negligence penalty under section 6653(a), Internal Revenue Code of 1954, of $78.40.
By stipulation the parties have settled all issues except one. The only question left for decision is whether petitioner Walter J. Moore must include in his income certain "royalties" based upon sales...
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