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SEMEL v. COMMISSIONER

Docket No. 5303-71.

33 T.C.M. 248 (1974)

T.C. Memo. 1974-52

Bernard J. Semel v. Commissioner.

United States Tax Court.

Filed February 28, 1974.

Attorney(s) appearing for the Case

Werner Strupp, 1705 DeSales St., N.W., Washington, D.C., for the petitioner. C.B. Norris, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for the calendar year 1967 in the amount of $7,840.99.

The only issue for decision is whether under the provisions of section 1239, I.R.C. 1954,1 petitioner should have treated a payment received in 1967 on an indebtedness arising from the sale of patents in 1964 to B.J. Semel Associates, Inc., as ordinary...

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