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FEDERAL OIL COMPANY v. COMMISSIONER

Docket No. 5466-64.

25 T.C.M. 996 (1966)

T.C. Memo. 1966-195

Federal Oil Company v. Commissioner.

United States Tax Court.

Filed August 31, 1966.

Attorney(s) appearing for the Case

Martin D. Cohen, 744 Broad St., Newark, N. J., for the petitioner. Donald H. Cuozzo and William M. Gross, for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in the income taxes of petitioner for the years 1960, 1961, and 1962 in the amounts of $16,739.74, $16,740, and $17,897.97, respectively. The sole issue is whether payments in the amount of $62,000 made to petitioner by Sinclair Refining Company in each of the years 1960, 1961, and 1962 were in consideration of a covenant not to compete or for the sale of goodwill.<...

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