This proceeding involves a redetermination of a deficiency in income tax of the petitioners in the amount of $2,785.52 for the taxable year 1949 and $3,298.52 for the taxable year 1950. The evidence consists of a stipulation of facts and exhibits received at the hearing. The question is whether the amounts received by petitioners in 1949 and 1950 from two sporting goods companies are taxable as ordinary income or as capital gain when such amounts were determined by the volume...
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