Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $1,425.38 in petitioners' Federal income tax for the year 1968.
At issue is whether the amount of $10,150.25 received in 1968 by petitioner Homer S. Deal for the cancellation of his agency management contract with Farmers Insurance Group is taxable as ordinary income or as a long-term capital gain.
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