SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1959, 1960, and 1961 in the amounts of $361.58, $361.57, and $216.95, respectively.
The issue for decision is whether petitioner Hoyt Butler received the amount of $9,641.99 as payment for goodwill of a one-half interest in his accounting practice which he conveyed to J. Edward Stowe pursuant to an oral agreement between the two for the formation of a...
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