OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1957 in the amount of $24,148.44.
Petitioners assign as error the following:
A. The Commissioner has erred in disallowing as a deduction from the petitioner's gross income for the taxable year ended December 31, 1957 the amount of $70,625.67 representing the basis of good will included in the sale of the taxpayers' business in 1957.
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