Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income taxes for the years 1970, 1971, and 1972 in the amounts of $982, $129, and $604, respectively. The sole issue for decision is whether respondent properly determined that a portion of the consideration received by petitioners under an installment sale of their insurance agency is allocable to a covenant not to compete and thus taxable as ordinary...
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