Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years ended April 30, 1959, April 30, 1960, and April 30, 1961, in the respective amounts of $4,565.65, $2,144.84, and $6,490.08.
The issue is whether, in connection with the purchase of a one-half interest in a corporation, the petitioner paid any amount for a covenant not to compete, entitling it to the deduction of a ratable...
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