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THRIFTICHECK SERVICE CORPORATION v. COMMISSIONER

Docket No. 74819.

33 T.C. 1038 (1960)

THRIFTICHECK SERVICE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 22, 1960.

Attorney(s) appearing for the Case

John T. Powell, Esq., and James D. St. Clair, Esq., for the petitioner.

James E. Markham, Jr., Esq., for the respondent.

ATKINS, Judge:

The respondent determined a deficiency in the petitioner's income tax for the fiscal year ended April 30, 1954, in the amount of $74,242.55. On brief the respondent conceded that the petitioner is entitled to a claimed deduction of $12,500 on account of a payment made under an agreement not to compete. There remain for decision the question whether petitioner is entitled to deduct, under section 23(1...

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