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MOLASKY v. COMMISSIONER

Docket No. 473-86.

55 T.C.M. 672 (1988)

T.C. Memo. 1988-173

Allan Molasky and Gloria Molasky v. Commissioner.

United States Tax Court.

Filed April 25, 1988.

Attorney(s) appearing for the Case

David C. Salivar, 12555 Manchester Rd., St. Louis, Mo., for the petitioners. Robert J. Burbank, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the 1981 taxable year in the amount of $208,524. The issue before us is whether and to what extent petitioner Allan Molasky recognized income under section 61(a)1 for payments allocated to a covenant not to compete in connection with a sale of a distributorship.

Findings of Fact

Some...

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