TAYLOR v. COMMISSIONER

Docket No. 2781-69.

29 T.C.M. 1488 (1970)

T.C. Memo. 1970-325

William W. Taylor and Gene W. Taylor v. Commissioner.

United States Tax Court.

Filed November 24, 1970.


Attorney(s) appearing for the Case

K. G. Seitz, 4321 Hamilton Ave., Cincinnati, Ohio, for the petitioners. Rudolf L. Jansen, for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies of $34.78 and $1,845.14 in petitioners' income tax for the calendar years 1965 and 1966, respectively. The only issue remaining for decision is whether amounts received by petitioner, William W. Taylor, in connection with the transfer of certain patent rights should be taxed as capital gain or ordinary income.

Findings of Fact

The parties have stipulated certain facts...

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