SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1962 in the amount of $32,474.78.
One of the issues raised by the pleadings has been disposed of by agreements of the parties, leaving for our decision the following:
(1) Whether the amount of $86,500 which Sherwood & Roberts, Inc., agreed to pay to petitioner for its mortgage-servicing business is in whole or in part in payment for the assignment...
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