BACON v. COMMISSIONER

Docket No. 1259-75.

36 T.C.M. 231 (1977)

T.C. Memo. 1977-52

George F. Bacon and Helen R. Bacon v. Commissioner.

United States Tax Court.

Filed March 2, 1977.


Attorney(s) appearing for the Case

John W. Sabo III, Daniel P. Edwards, and Bruce N. Warren, for the petitioners. Charles H. Cowley, for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income taxes for the years 1970, 1971, and 1972 in the amounts of $982, $129, and $604, respectively. The sole issue for decision is whether respondent properly determined that a portion of the consideration received by petitioners under an installment sale of their insurance agency is allocable to a covenant not to compete and thus taxable as ordinary...

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