OPINION
TANNENWALD, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1962 in the amount of $3,810.97. The sole question is whether certain sums, characterized in the pertinent agreements as payments for a covenant not to compete and an undertaking to be available for consultation, should be classified as ordinary income or whether said sums were in reality part of the consideration for the sale of the patent and/or...
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