Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1958 in the amount of $6,066.70. The issues are (1) whether a portion of the proceeds received by petitioner from the sale of his armored car business represented a payment for goodwill or a payment for a covenant not to compete; and (2) whether respondent was correct in disallowing the depreciation claimed by petitioner...
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