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ENYART v. COMMISSIONER

Docket No. 4336-98.

79 T.C.M. 1656 (2000)

T.C. Memo. 2000-90

William R. & Carol Enyart v. Commissioner.

United States Tax Court.

Filed March 14, 2000.

Attorney(s) appearing for the Case

Benjamin R. Cooksey, for the petitioners. Mary Ann Waters, for the respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

Respondent determined a deficiency in, and an accuracy-related penalty under section 6662(a)1 on, petitioners' Federal income tax (tax) for 1992 in the amounts of $88,442 and $17,688, respectively.

The issues remaining for decision are:

(1) Are petitioners required to include in their taxable income for the year at issue the amount of $300,000 as consideration for the covenant...

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