MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a Federal income tax deficiency for petitioners' 1993 taxable year in the amount of $120,439. Respondent also determined an accuracy-related penalty of $24,088 for 1993, pursuant to section 6662(a).
The issues for decision are as follows:
(1) Whether the sale of a business by a charitable remainder unitrust resulted in taxable income to petitioners by reason of a covenant...
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