The Commissioner determined deficiencies in income tax of $68.70 for 1943 and $80,746.77 for 1944. The questions for decision are:
(1) Whether the net proceeds of a patent infringement suit, in the amount of $107,825.29, are taxable income or a nontaxable return of capital.
(2) If they are taxable income, whether they are to be taxed as ordinary income or as capital gains resulting from an involuntary conversion within the meaning of section 117 (j).
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