Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies of $2,926 for 1960 and $3,131 for 1961 in petitioners' income tax. The question presented is whether royalties received by petitioner in 1960 totaling $17,022 and in 1961 totaling $15,270 under an agreement distributed to petitioner in 1946 on the liquidation of Waring Corporation constitute ordinary income or capital gain.
Findings of Fact
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