Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year ending January 31, 1968, in the amount of $38,512.26. The two issues presented for decision are as follows:
(1) Whether part of the consideration received by petitioner Arthur L. Sigman under an agreement for the redemption of his stock in Sigman Meat Company, Inc., is allocable to a covenant not to...
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