OPINION.
RAUM, Judge:
The Commissioner determined deficiencies in income tax for 1951 against petitioners as follows:
James A. Skannel -------------------------- $5,648.82 Arron and Helen Benton -------------------- 4,163.48
The question for decision is whether the payment of $17,500 to Skannel and Arron Benton in connection with their relinquishment of rights under a distributorship agreement represents ordinary income...
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