Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the taxable year 1973 in the amount of $159,005.58.
The sole issue for decision is whether petitioner may allocate a portion of the purchase price, which its purchase contract designates it paid for stock, to a covenant not-to-compete.
Findings of Fact
Petitioner Stryker Corporation is a corporation duly incorporated...
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