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BRAMS v. COMMISSIONER

Docket No. 9639-77.

41 T.C.M. 678 (1980)

T.C. Memo. 1980-584

Nathaniel Brams and Eireen Brams v. Commissioner.

United States Tax Court.

Filed December 30, 1980.

Attorney(s) appearing for the Case

Bernard A. Kansky, 131 State St., Boston, Mass., for the petitioners. Thomas P. Dougherty, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $27,499.50 in petitioners' 1973 income tax. The sole issue to be decided is the proportion of proceeds received by petitioners upon the sale of their family business which is properly allocable to a covenant not to compete.

Findings of Fact

Some of the facts have been stipulated and are found accordingly.

Petitioners were married and...

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