Rider v. Commissioner of Internal Revenue

GARDNER, Chief Judge.

This is a petition to review a decision of the Tax Court redetermining deficiencies in petitioner’s income taxes for the years 1945, 1946 and 1947. The question presented to the Tax Court for decision was whether the income from certain contracts with book publishers received by the taxpayer was taxable as ordinary income or as capital gains.

Taxpayer is a professor of mathematics at Washington University, located in St. Louis, Missouri, and has held that position since 1917, and as such has been engaged in the teaching profession. He has devoted all the time necessary in…