Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1963 in the amount of $1,209.28.
Since respondent has conceded one of the issues raised by the pleadings, the only issues for decision are:
(1) Whether an amount of $14,500 received by petitioner in 1963 from Air Reduction Co., Inc., in return for a general release of that...
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