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CHILTON v. COMMISSIONER

Docket No. 91332.

40 T.C. 552 (1963)

ROLAND CHILTON AND FLORENCE CHILTON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 21, 1963.

Attorney(s) appearing for the Case

Theodore Tannenwald, Jr., and John J. White, for the petitioners.

Henry L. Glenn, for the respondent.

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1954, 1955, 1956, and 1957 in the amounts of $48,873.52, $35,589.50, $2,400.96, and $717.02 respectively.

The issue for decision is whether amounts received in the years here involved by Roland Chilton pursuant to contracts with his employers constitute ordinary income as compensation or long-term capital gains from the sale or exchange of patents.

FINDINGS...

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