PARKER, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals; and the question involved is whether a payment of $50,000 made to taxpayer was a gift or additional compensation for services rendered. Taxpayer is a patent attorney who over a period of years had rendered services to the Universal Oil Products Company, a corporation whose chief property consisted of certain patents and patent rights. In 1931 the stockholders of that corporation...
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