This proceeding involves a deficiency in income tax in the amount of $8,664.46 for the year 1946 determined against Curtis B. Dall (hereinafter referred to as the petitioner).
The only issue to be decided is whether petitioner is entitled to report taxable income in the amount of $15,235.42, received by him in 1946, as compensation for personal services rendered over a 36-month period within the meaning of section 107 (a)
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