Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Year Deficiency 1974 .............. $40,511 1975 .............. 21,361 1976 .............. 3,582 1977 .............. 9,837
The issue for decision is whether amounts received by petitioner Louis J. Michot upon termination of franchising agreements are taxable...
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