- 17 -
executed by Dr. Donald L. Chiappetti", as they clearly did in
exhibit A to that contract.
Based on our examination of the entire record before us, we
find that petitioners have failed to sustain their burden of
proving error in respondent's determinations that they must
recognize income of $14,522 and $38,248 for 1990 and 1991, re-
spectively, that is attributable to petitioner's covenant not to
compete.9 We therefore sustain those determinations.
To reflect the foregoing,
Decision will be entered
for respondent.
9 We have considered all of petitioners' other arguments not
discussed herein and also find them to be without merit.
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