OPINION.
TIETJENS, Judge:
The Commissioner determined a deficiency in petitioner's income tax for the year 1954 in the amount of $6,500. The only question is whether the amount of $25,000 received in 1954 by the petitioner from the William Morris Agency, Inc. (hereinafter referred to as the Morris Agency), is taxable as capital gain or ordinary income.
All the facts have been stipulated, are so found, and are incorporated herein by reference...
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