OPINION
FAY, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1962 in the amount of $69,336.67.
Certain issues raised in the pleadings have been disposed of by agreement of the parties prior to the trial herein. The sole issue left for decision is whether $67,800 realized by petitioner upon the assignment of Muzak subscribed contracts which were separately bargained for on the sale and assignment of...
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