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KINNEY v. COMMISSIONER

Docket No. 2935-68.

58 T.C. 1038 (1972)

HARRY A. KINNEY AND BETTY W. KINNEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 26, 1972.

Attorney(s) appearing for the Case

Charles W. Hall and Augustus T. Blackshear, Jr., for the petitioners.

Leslie A. Plattner, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $49,200.34 in the petitioners' 1962 Federal income tax. The only issue for decision is what portion, if any, of the amount paid for an insurance agency is allocable to the covenant not to compete.

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioners, Harry A. and Betty W. Kinney, are...

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