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respondent for 1988 and 1989 are $78,759 and $245,068,
respectively.
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
After an agreement between the parties,1 the issue for
decision is whether petitioner is entitled to deductions for
amortization of amounts paid to William Wright for a
noncompetition and consulting agreement. We hold that it is to
the extent set out below.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulated
facts and the accompanying exhibits are incorporated into our
findings by this reference. At the time of the filing of the
petition, petitioner, Heritage Auto Center, Inc., maintained its
principal place of business in Gladstone, Oregon.
During the years at issue, petitioner had four shareholders:
E.W. Richardson, Bob Turner, Kenneth Blewett, and Wade Zellner
(Mr. Richardson, Mr. Turner, Mr. Blewett, and Mr. Zellner). At
the date of trial, each one of these individuals had significant
experience in the automobile dealership business. Mr. Richardson
had been in the automobile dealership business for approximately
1 We leave it to the parties to include their agreed adjustments in their
Rule 155 computations.
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