Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $5,000 in petitioners' Federal income tax for the year 1971. At issue is whether $20,000 of a sales price of $71,177.32 for an insurance business sold by petitioner Morton F. McKinney's wholly owned corporation to the Mahoning Valley Agency, Inc. in 1971 should be treated as having been paid for a non-competition covenant, taxable as ordinary income, or paid for...
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