United States Tax Court January 27, 1965, Docket No. 989-63 (Bellamy v. Commissioner)

lead-opinion

AteiNS, Judge:

The respondent determined a deficiency in income tax for the taxable year 1957 in the amount of $44,864.77.

The parties having reached agreement as to certain issues, the issue remaining for decision is whether the sum of $89,000 paid to the petitioner Ralph Bellamy in 1957 was proceeds from the sale by him of property which was a capital asset, resulting in the