Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for 1980 and 1981 in the amounts of $19,774 and $29,948, respectively. The issues for decision are: (1) whether petitioner, a fuel oil distributor, is entitled to amortize customer lists acquired in connection with the purchase of various assets of two competitors; and (2) whether petitioner may deduct the remaining amount owed under...
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