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KACZMAREK v. COMMISSIONER

Docket No. 6209-77.

43 T.C.M. 501 (1982)

T.C. Memo. 1982-66

Alvis Kaczmarek and Aleita Kaczmarek v. Commissioner.

United States Tax Court.

Filed February 11, 1982.

Attorney(s) appearing for the Case

Leonard Cuttone, 100 N. LaSalle St., Chicago, Ill. for the petitioners. Val J. Albright, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal income tax against petitioners for 1973 in the amount of $17,327. After concessions by both sides, the issues for decision are as follows:

(1) Whether amounts received under an agreement with a Japanese company with respect to an invention and related technology and know-how, qualify for treatment as long-term capital gains under section 1235 or...

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