Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the calendar year 1976 in the amount of $11,853. The issues for decision are: (1) whether and to what extent amounts paid by petitioners in 1976 to indemnify the purchasers of petitioners' business, the proceeds of which were properly reported as being from the sale of a capital asset in 1973, are allowable as a capital...
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