Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $1,190.94 in the income tax of petitioners for the year 1950. The only issue for decision is whether the amount of $10,000 received by petitioners during that year for a covenant not to compete was taxable as ordinary income or as capital gain from the sale of their business.
Findings of Fact
The petitioners are husband and wife and reside in East Haven, Connecticut...
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