The Commissioner determined deficiencies in income tax for the calendar years 1951 and 1952 in the amounts of $21,092.88 and $16,457.16, respectively. Petitioners contest the entire deficiencies and claim further that there is overpayment of $7,202.40 for 1951 and $3,564.76 for 1952.
The questions are: (1) Whether either or both of two transfers of rights in patents constituted sales or merely licensing agreements. The Commissioner has determined that only licensing...
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