Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies have been determined by respondent in the income tax of petitioners for the taxable years 1955 and 1956 in the respective amounts of $10,878.34 and $18,178.43.
The only issue to be decided is whether respondent has erred in refusing to permit capital gains treatment of certain amounts paid to Paul Tilles (hereinafter referred to as petitioner) under the terms of an agreement dated...
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