Respondent determined deficiencies in petitioner's income tax liability for the calendar years 1941 and 1943 in the amounts of $934.04 and $1,532.85, respectively. The sole question is whether petitioner properly applied the provisions of section 107 of the Internal Revenue Code to compensation received for personal services rendered over a period of years. An affirmative issue with respect to a penalty for the year 1943 was waived by respondent at the hearing. Two minor...
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