Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $13,677.33 for the calendar year 1966.
The issue for decision is whether $47,500 of an amount of $50,000 paid by Cities Service Oil Company to petitioner during the calendar year 1966 constituted ordinary income or capital gains.
Findings of Fact
Some of the facts have been stipulated and are...
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