MULRONEY, Judge:
The respondent determined a deficiency in the petitioner's income tax for the year 1956 in the amount of $27,009.34. The issues are:
(1) Whether the entire fair market value of a contract under which petitioner obtained the right to receive an annual fixed amount over a period of 15 years is includible in petitioner's gross income in the year the contract was effective, and
(2) Whether the amount received by the petitioner is...
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