Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined an income tax deficiency for petitioner's taxable year ended February 28, 1982 in the amount of $114,397.54. The sole issue is whether petitioner properly allocated the price it received for its business between its depreciable and nondepreciable assets. Respondent contends petitioner allocated too little to depreciable assets and too much to goodwill, resulting in the underreporting...
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