This section contains the nature of the case and procedural background.

Harahan got a judgment against Cole for $75,702.12. Ps then purchased the judgment from the residuary legatees of Harahan's estate. Their aggregate cost of the judgment was $11,004, and this included attorney fees and expenses of $1,004. Cole eventually paid the sum of $21,150 as a full and final settlement of the judgment. Ps then reported this profit as a long-term capital gain on their 1945 tax returns. The IRS claimed a deficiency as the amount was taxable as ordinary income.

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