Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioners' income tax for the calendar year 1951 in the amount of $9,348.82. The issues for decision are (1) whether the petitioner Murray T. Morgan worked on the meat-curing process covered by his Mexican Patent No. 49835 for 36 calendar months; (2) if so, whether the payments received by him in the taxable year pursuant to paragraph 4 of certain contracts granting to three Mexican...
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