Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies of $1,540 and $3,092 in petitioner's Federal income taxes for 1975 and 1976, respectively. Due to concessions by petitioner, the sole issue for decision is whether petitioner is entitled to deduct, as an ordinary business expense, payments purportedly made as consideration for a covenant not to compete.
Findings of Fact
At the time of filing its...
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