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consideration of the payment of a contract value amount).
Petitioners have failed to introduce evidence of vendible assets
or show language referencing a contract of sale. That is
sufficient for us to conclude that petitioner received no payment
for any property. See Schelble v. Commissioner, T.C. Memo. 1996-
269, affd. 130 F.3d 1388 (10th Cir. 1997). We reach the same
conclusion that we reached in Farnsworth v. Commissioner, supra,
also involving a district manager’s agreement, that neither in
form nor in substance did the cancellation of the agreement give
rise to the sale of property by petitioner. See also Clark v.
Commissioner, supra.
We sustain in full the deficiencies in tax determined by
respondent.
Decision will be entered
for respondent.
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Last modified: May 25, 2011