Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1957 in the amount of $2,515.68. The sole issue remaining for decision is whether $6,000 received by petitioner pursuant to an agreement for the sale of his accounting practice is taxable as ordinary income or capital gain.
All other issues raised by the pleadings have been settled by agreement between the parties...
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