Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1959 in the amount of $24,810.15. The issue for decision is whether any portion of the amount of $71,140 received by the petitioner Fitzgerald Atkinson pursuant to an agreement for the sale of his interest in a general insurance agency partnership, was either consideration for his covenant not to compete, an amount guaranteed...
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