PER CURIAM.
This is an appeal from the decision of the United States Tax Court upholding the Commissioner's determinations of deficiency and transferee liability for the years 1964-66.
The taxpayers contracted to sell their insurance agency. It was agreed in writing that 80 per cent of the sale price was the consideration for a covenant by the taxpayers not to compete. Reference is made to the Tax Court opinion, 39 P-H Memo TC 1340, ¶ 70,273 (1970), for...
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