The respondent determined a deficiency in income tax against the petitioners for the taxable year 1944 in the amount of $13,770.50. The petitioners claim an overpayment of income taxes for that year in the amount of $7,699.06. The only issues presented for our decision are whether the amount of $42,057.66 derived from the publication of the book "Persons and Places," or a part thereof, is taxable income of the petitioners for the year 1944 and, if so, whether as capital gain...
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