The Commissioner determined a deficiency in petitioner's income tax for 1947 in the amount of $19,851.34. The issues for decision are:
1. Whether upon the sale of a business conducted by the petitioner as a sole proprietorship the consideration received by him in excess of the basis of the assets thereof was long-term capital gain or ordinary income as either: (a) A payment made to induce him to enter into a contract; (b) advance compensation for services to be rendered...
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