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SCOTT v. COMMISSIONER

Docket No. 53931.

26 T.C. 869 (1956)

DON O. SCOTT AND ANNE B. SCOTT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 26, 1956.

Attorney(s) appearing for the Case

Spencer E. Irons, Esq., for the petitioners.

Andrew Kopperud, Jr., Esq., for the respondent.

The respondent determined a deficiency of $7,109.31 in the income tax of the petitioners for the calendar year 1951.

The sole issue for decision is whether all or any part of certain payments aggregating $21,589.56, which petitioner Anne B. Scott received from Avco Manufacturing Corporation in the year involved, represented proceeds from a sale by her to said corporation of interests in a patent, so as to entitle said payments...

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