DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1949 in the amount of $10,280,673.27. The deficiency results from respondent's determination that petitioner was not an exempt organization in 1949 and that an accumulation of patent royalties and infringement claims, totaling $15,366,841.12, which had been paid into the registry of various courts by orders of those courts in various patent litigations and which were...
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