SIMPSON, Judge:
The respondent determined a deficiency in the petitioners' income tax for the taxable year ending December 31, 1962, in the amount of $5,423.57. The sole issue for decision is whether the petitioner, Mr. Milberg, transferred all substantial rights to his interest in a patent to the Fitzgerald Underwear Corp., and is therefore entitled to treat payments received for the rights transferred as gain from the sale or exchange of a capital asset....
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