ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1963 and 1964 in the respective amounts of $2,406.69 and $8,293.63.
The sole issue for decision is whether payments totaling $50,000 received by the petitioner Edmond C. Maseeh in 1963 and 1964 constituted payment for an agreement not to compete and hence ordinary income as determined by the respondent, or proceeds from the sale of goodwill of a business, and hence...
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