Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' 1972 income tax in the amount of $4,839.31. Concessions having been made, the sole issue remaining for our decision is whether payments received by petitioner Alfred P. Blair during 1972 were payments in consideration for a covenant not to compete, taxable as ordinary income.
Findings of Fact
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