Memorandum Findings of Fact and Opinion
The respondent has determined a deficiency in income tax against petitioner in the amount of $429.16 for the year 1939; and petitioner claims he is entitled to a refund of $215.58. The only question presented is whether payments received by petitioner, under a certain contract, constituted ordinary income or a capital gain.
Findings of Fact
Petitioner, during the taxable year, was a resident of New York,...
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