ARUNDELL, Judge:
In these consolidated proceedings respondent determined deficiencies in income tax for the calendar years 1959 and 1960 of $571 and $694.55, respectively.
The only issue to be decided is whether certain amounts received by petitioners for the alleged transfer of patent rights are taxable as ordinary income or as long-term capital gains from the sale of capital assets.
FINDINGS OF FACT
The stipulated facts, together...
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