FORRESTER, Judge:
Respondent has determined a deficiency in petitioner's Federal income tax for its fiscal year ended July 31, 1971, in the amount of $4,115.44. Concessions having been made, the only issue remaining for our decision is whether a $25,000 payment made to petitioner by a foreign corporation was paid for the transfer of petitioner's Japanese patent rights and other property and, if so, whether such transfer constituted a sale so that such amount...
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