CARSWELL, District Judge.
The sole issue for review here is whether $12,500 received by the taxpayer in connection with an agreement of sale and dissolution of a partnership engaged in the insurance business should be taxed as capital gain or as ordinary income.
Upon a full record, the Tax Court entered its findings and concluded that what was sold in this instance was a capital asset under Title 26 United States Code § 1221.
Although there is...
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