This proceeding involves a deficiency in income tax for the calendar year 1939 in the amount of $1,316.78. The deficiency is the result of a single addition of $5,908.05 to income which the respondent, in a statement attached to the deficiency notice, explained as follows:
It is held that royalties in the amount of $5,908.05 payable to you by The Stayform Company during the taxable year under the terms of a contract entered into between you and The Stayform Company...
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