Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in the Federal income tax of Charlotte Corporation for the year 1950 in the amount of $31,485.24 by characterizing $100,000 (reported as long-term capital gain from the sale of good will) as ordinary income from the sale of inventories.
On the inconsistent ground that part of the purchase price was in payment for good will, respondent has determined deficiencies...
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