Memorandum Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1966 and 1967 in the respective amounts of $22,402.38 and $65,282.88. The only issue to be decided is whether certain proceeds from the sale of rights to a patent application should be treated as ordinary income under section 1239, Internal Revenue Code of 1954, or should be taxed as capital gains.
All of the facts have been stipulated...
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