MAGRUDER, Chief Judge.
The Commissioner asks us to review a decision of the Tax Court entered August 10, 1955, concluding that there is no deficiency in the income tax of Franklin A. Reece for the calendar year 1947. In determining a deficiency, the Commissioner had ruled that certain "royalty" income paid to the taxpayer's wife pursuant to an assignment must be attributed to the taxpayer and included in his gross income for the year 1947. The Tax Court held otherwise...
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