MacDonald v. Commissioner

DawsoN, Judge:

In these consolidated cases respondent determined the following Federal income tax deficiencies:

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Pursuant to leave granted at the trial, respondent claims the following increased deficiencies:

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The first issue for decision is whether transfers by petitioners of all their rights in certain patents constituted' a sale of either capital assets held for more than 6 months or of section 1231 assets, the gain from which is taxable to petitioners as long-term capital gain, or whether the transfers were something less than a sale, thus causing the gain to be…