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FIDLER v. COMMISSIONER

Docket No. 3887-77.

40 T.C.M. 1080 (1980)

T.C. Memo. 1980-346

Gilbert E. Fidler, Sr., and Mary O. Fidler v. Commissioner.

United States Tax Court.

Filed August 28, 1980.

Attorney(s) appearing for the Case

Charles Crehore and Yale F. Goldberg, 100 W. Washington St., Phoenix, Ariz., for the petitioners. Matthew Magnone, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1972 in the amount of $10,751. Concessions having been made, the only issue remaining for decision is whether any portion of the sale price of petitioners' unincorporated business must be allocated to a covenant not to compete.

Findings of Fact

Some of the facts have been stipulated and...

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