Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $86,718.15 in petitioner's income tax for 1940. The Commissioner (1) refused to apply the 50 per cent capital gain provision of Section 117, Internal Revenue Code, to an amount received by petitioner from the United States in payment of a claim for use of a patent and treated the amount received as 100 per cent taxable as ordinary income, and (2) disallowed deductions for attorney...
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