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WALKER v. COMMISSIONER

Docket No. 43400.

13 T.C.M. 558 (1954)

T. C. Memo. 1954-71

Lloyd H. Walker and Gretchen C. Walker v. Commissioner.

United States Tax Court.

Filed June 21, 1954.

Attorney(s) appearing for the Case

Harold A. Pebbles, Esq., and C. L. Stickney, C. P. A., 521 Security Building, Olympia, Wash., for the petitioners. John H. Pigg, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income tax against petitioners for the taxable years 1947, 1948, and 1949 in the respective amounts of $299.82, $307.22, and $285.04. The sole issue is whether the sum of $8,000, representing part of the purchase price paid upon the acquisition of an insurance and bonding business, is depreciable over the 5-year period of a covenant not to compete.

Findings...

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