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William M. BAILEY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

PER CURIAM.

There is ample evidence to support the findings of the Tax Court that petitioner had not made an outright sale of his invention as he claims and that, therefore, the proceeds of the transaction are taxable to him as ordinary income. The decision of the Tax Court will be affirmed.

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BAILEY v. COMMISSIONER OF INTERNAL REVENUE
(May 1, 1951)