Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined a deficiency of $29,542.01 in income tax for 1941, in part by adding to income reported one-fourth of certain royalties which were paid for the use of patents issued to petitioner and which were credited on his books to his wife. Petitioner assails the determination, contending that he had made an effective sale and assignment of a one-fourth interest in the patents to his...
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