The respondent determined deficiencies in the income taxes of the petitioners for the calendar years 1951 and 1952, in the respective amounts of $9,025.53 and $14,059.87.
The issue for decision is whether payments of $33,526.65 and $44,920.28, which petitioner Frank H. Philbrick received in the taxable years 1951 and 1952, respectively, under the terms of an exclusive patent license agreement, are taxable as long-term capital gains, or as ordinary income from "royalties...
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