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JOHNSON v. COMMISSIONER

Docket No. 2303-65.

49 T.C. 324 (1968)

JAMES A. JOHNSON AND PEARL J. JOHNSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 3, 1968.

Attorney(s) appearing for the Case

Kenneth L. A. Mitchell, for the petitioners.

Bert L. Kahn, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income tax for the year 1961 in the amount of $3,389.39 and for the year 1962 in the amount of $428.25.

The issue is whether payments made by a purchaser to petitioner, pursuant to a written contract of sale whereby petitioner sold three categories of business assets, should be ratably allocated by petitioner to the three categories according...

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