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CITIZENS ASSURANCE, INC. v. COMMISSIONER

Docket No. 8751-83.

50 T.C.M. 1 (1985)

T.C. Memo. 1985-260

Citizens Assurance, Incorporated v. Commissioner.

United States Tax Court.

Filed June 3, 1985.

Attorney(s) appearing for the Case

Frank L. Farrar and Israel E. Krawetz, 318 Railway St., Enderlin, N. D., for the petitioner. Stuart D. Gibson, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency in petitioner's 1979 Federal income taxes of $8,905.83, and an addition to tax under section 6651 (a)1 of $890.58. After concessions, the issues for decision are (1) whether one-half of the amount petitioner paid to purchase an insurance business was paid for a covenant not to compete, and (2) whether petitioner has shown that it filed its...

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