Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1966 in the amount of $21,600. The sole issue for decision is whether an amount received by petitioner in respect of a covenant not to compete provided for in a contract of sale of certain radio and television stations is taxable as ordinary income or is to be treated as capital gain with the consequence that it is relieved of tax by...
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