Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1985 and 1986 in the amounts of $27,817 and $889, respectively. The issue for decision is whether the sale made by petitioner to Mr. Ernest Johns was the sale of a capital asset or was the sale of a computer program, an asset which is excludable from the definition...
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