KERSHAW v. COMMISSIONER

Docket No. 73509.

34 T.C. 453 (1960)

ROYCE KERSHAW AND MIRIAM KERSHAW, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 8, 1960.


Attorney(s) appearing for the Case

Fred S. Ball, Jr., Esq., for the petitioners.

Homer F. Benson, Esq., for the respondent.


OPINION.

PIERCE, Judge:

The respondent determined a deficiency in the petitioners' income tax for the year 1956 in the amount of $18,843.76.

The sole issue for decision is whether amounts received in the taxable year 1956 by the principal petitioner from his controlled corporation, pursuant to a contract whereby he sold and assigned to such corporation all rights to a patent developed by him, are taxable to said petitioner-inventor as ordinary...

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