Memorandum Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1988 Federal income taxes of $1,051. The sole issue raised by respondent is whether petitioner may deduct, on her individual income tax return, the amortized cost of a noncompetition...
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