OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes for the calendar years 1965 and 1966 in the amounts of $851.32 and $2,880.25, respectively.
The only issue for decision is whether a portion of the payments received by petitioners during the years 1965 and 1966 under a license agreement whereby they disposed of substantially all rights in certain patents was unstated interest under the provisions of section...
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