Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income tax for 1953 in the amount of $1,755.15. The sole issue is whether payments received by Curt A. Claus were taxable as ordinary income or as capital gain from the sale of an interest in patents issued to Walter E. Claus, his brother. The joint return of the petitioners was filed with the director of internal revenue for the District of Wisconsin, at Milwaukee...
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