WITHEY, Judge:
The Commissioner has determined a deficiency in the income tax of petitioner for the fiscal year ended October 31, 1954, in the amount of $271,269.67. The only issue here presented is whether the amount of $1 million paid it under the terms of a contract constitutes ordinary income or capital gain.
FINDINGS OF FACT.
The stipulated facts are found as stipulated.
The petitioner, the Heil Co., is a corporation organized...
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