The Commissioner determined deficiencies in petitioner's income tax as follows:
Year Deficiency 1966 ------------------------------ $962.86 1967 ------------------------------ 3,172.55 1968 ------------------------------ 3,094.40 1969 ------------------------------ 3,101.96
The sole issue for decision is whether the amounts paid by petitioner O'Dell & Co. pursuant to a dual covenant to perform...
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