This proceeding involves a deficiency in income tax in the amount of $236,382.81 determined against the petitioners for the year 1948. The only issue is whether any part of the amounts paid by the Columbia Broadcasting System, Inc., and Columbia Records, Inc., to the stockholders of Amusement Enterprises, Inc., for the sale of its stock to such corporations, was taxable as ordinary income to petitioner, Jack Benny, as compensation for his services.
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