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BLAKE v. COMMISSIONER

Docket No. 8235-74.

67 T.C. 7 (1976)

DAVID R. BLAKE AND BETTY H. BLAKE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 6, 1976.

Attorney(s) appearing for the Case

David R. Blake, pro se.

Thomas R. Ascher, for the respondent.

TANNENWALD, Judge:

Respondent determined deficiencies of $1,447.20 and $26,177.38 in the petitioners' Federal income taxes for 1969 and 1970, respectively. The issues now presented for decision are:

(1) Whether amounts received with respect to certain patent licensing agreements are taxable as long-term capital gain under section 12351 or as ordinary income;

(2) Whether a portion...

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