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DEVINE v. COMMISSIONER

Docket No. 424-72.

34 T.C.M. 1077 (1975)

T.C. Memo. 1975-251

Judy Devine v. Commissioner.

United States Tax Court.

Filed July 30, 1975.

Attorney(s) appearing for the Case

Frederick P. Durant, P.O. Box 279, Plainview, Tex., for the petitioner. W. John Howard, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioner's Federal income taxes as follows:

  Year                    Deficiency

  1965 .................. $10,948.44
  1966 ..................  38,649.97
  1967 ..................  21,303.77

The sole issue for decision is whether petitioner realized ordinary income or capital gains from the transfers of licensing rights to Icee...

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