The respondent determined deficiencies in income tax against the petitioners for the calendar years 1951, 1952, and 1953 in the respective amounts of $96,618.24, $133,698.04, and $128,199.20. The only question remaining is whether payments received by the petitioners in the aggregate amount of $42,000 for each of the taxable years 1951, 1952, and 1953 under a so-called modification agreement, pertaining to certain patents, applications for patents and rights, constituted...
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