Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined differences in petitioners' income tax of $18,540 for the taxable year ended June 30, 1972 and $16,481.34 for the taxable period ended February 28, 1973. After concessions by petitioners, the sole issue for decision is whether petitioners are entitled to an amortization deduction in respect of a covenant not to compete.
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