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MAIN BROTHERS OIL COMPANY, INC. v. COMMISSIONER

Docket No. 6862-80.

43 T.C.M. 1426 (1982)

T.C. Memo. 1982-279

Main Brothers Oil Company, Inc. v. Commissioner.

United States Tax Court.

Filed May 19, 1982.

Attorney(s) appearing for the Case

Matthew H. Mataraso, 111 Washington Ave., Albany, N.Y., for the petitioner. Bradford A. Johnson, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Chief Judge:

Respondent determined a deficiency of $15,018.03 in petitioner's Federal income tax for the year ended June 30, 1977. The sole issue for our determination is the proportion of proceeds received by petitioner upon the sale of Peoples Gasoline and Oil which is properly allocable to a covenant not to compete.

Findings of Fact

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

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