United States Tax Court.
Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax of $1,960.34 for 1948 and $276.40 for 1949. The parties stipulated settlement of all issues except one. The remaining issue is whether respondent erred in allocating to a covenant not to compete a portion of the proceeds from a transaction in which Sidney Alper sold his stock in a corporation.
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