The Commissioner determined a deficiency of $1,614.37 in income tax of the petitioners for 1958. The only issue for decision is whether an amount received by Charles from Harry C. Miller was long-term capital gain, as reported by the petitioners, or was ordinary income (a) as payment for past services and for "unrealized receivables," as determined by the Commissioner, or (b) under sections 702, 736, and 1222 as claimed by the Commissioner in an amended answer filed on the...
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