This proceeding involves a deficiency in income tax for 1940. Leland J. Allen (hereinafter referred to as petitioner) filed a return reporting legal fees received $3,249.32; expenses $1,205.12; royalties $279.22; gross income $2,323.42; deductions $1,650.53; and net income $672.89. In an attached schedule he reported the receipt of a fee of $32,178.64 in oil royalties, covering services performed over a period of eight years. He computed his tax pursuant to section 107 of...
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