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ATKINSON v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 5528-10.

T.C. Memo. 2012-226

PETER Y. ATKINSON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 7, 2012.

Attorney(s) appearing for the Case

Mitchell Bryan and Michael J. Tuchman , for petitioner.

Lawrence C. Letkowicz , for respondent.

MEMORANDUM OPINION

KROUPA, Judge.

This matter is before the Court on respondent's motion for partial summary judgment under Rule 121.1 Respondent determined deficiencies of $686,535 and $140,049 in petitioner's Federal income tax for 2000 and 2001 (years at issue), respectively. Petitioner, a Canadian citizen and resident, received payments purportedly in exchange for entering into covenants not to compete (noncompete agreements...

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