This proceeding involves deficiencies in income tax for the years 1943, 1944, and 1945 in the amounts of $3,166.07, $105,582.25, and $89,301.50, respectively. Petitioner claims overpayments of $59,910.69 for 1943 and of $62.97 for 1945. The issues presented are (a) whether certain payments received by petitioner from Henry Disston & Sons, Inc., during the years 1943 to 1945, inclusive, constituted ordinary income, or were capital gain representing the consideration received...
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