The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1940 in the amount of $9,563.53. Petitioner conceded the correctness of the Commissioner's action in including in his taxable income the amount of $3,686.67 representing salary, but contends the respondent erred in including royalties in the amount of $8,678.30 as income from sources within the United States and royalties in the amount of $7,642.60 which petitioner contends were constructively...
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