DAWSON, Judge:
Respondent determined a deficiency of $375 in petitioners' income tax for the year 1959. The parties have conceded certain issues which can be given effect in the Rule 50 computation. Two issues remain: (1) Whether payments of $12,750 received by petitioner in 1959 from the American Metal Products Co. were consideration for the transfer of all substantial rights to a patent under the provisions of section 1235, I.R.C. 1954,
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