Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency of $969 in petitioners' Federal income tax for taxable year 1971. The only issue for decision is whether petitioners may allocate a portion of the purchase price of an insurance agency to a covenant not to compete, thereby enabling petitioners to claim amortization deductions.
Findings of Fact
Some of the facts have been stipulated. The stipulation...
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