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HELLER v. COMMISSIONER

Docket No. 74301.

18 T.C.M. 1139 (1959)

T.C. Memo. 1959-238

Robert H. Heller and Mary V. Heller v. Commissioner.

United States Tax Court.

Filed December 23, 1959.

Attorney(s) appearing for the Case

Lester M. Ponder, Esq., for the petitioners. Robert E. Johnson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in petitioners' income taxes as follows:

  Year                        Deficiency
  1953 ...................    $  366.78
  1954 ...................     1,558.40
  1955 ...................     1,190.32

The only question is whether certain weekly payments made by petitioners constituted a portion of the purchase price of an insurance agency, or were compensation...

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