Respondent determined a deficiency in petitioner's income tax for 1953 of $106,802.78. The issues are: (1) Whether the amount of $151,938.74 received in 1953 by petitioner constituted a long-term capital gain from the sale or exchange of a capital asset within section 117, I.R.C. 1939, or compensation for services rendered and taxable as ordinary income; (2) whether an accrual by petitioner, on a cash method of accounting, of 1953 foreign taxes, in addition to amounts paid...
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