Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency in petitioners' joint Federal income tax return for 1977 in the amount of $75,577.80. After concessions, two issues remain: (1) whether a payment of $631,383.80 constitutes consideration for a covenant not to compete, compensation for personal services, or payment in exchange for stock, and (2) if the payment is consideration for the covenant not to compete,...
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