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J. S. L. RESTAURANTS, INC. v. COMMISSIONER

Docket No. 23382.

10 T.C.M. 180 (1951)

J. S. L. Restaurants, Inc. v. Commissioner.

United States Tax Court.

Entered February 28, 1951.

Attorney(s) appearing for the Case

J. Stanley Halperin, Esq., 46 Cedar St., New York 5, N. Y., for the petitioner. Joseph Rogers, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Petitioner seeks redetermination of deficiencies for 1944 and 1945 of $761.21 and $756.46, respectively. The issues are whether a certain agreement constitutes a bona fide covenant not to compete so that petitioner is entitled to amortize its cost, and whether respondent properly disallowed various deductions for interest expense. Some of the facts have been...

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