Respondent has determined deficiencies for the taxable year July 1 to December 31, 1942, and for the calendar year 1943 in the respective amounts of $67,469.33 and $85,416.42. Two issues are presented: (a) Whether claimed deductions of $19,185.25 and $37,584.60 for alleged royalties paid to petitioner's stockholders in the taxable years 1942 and 1943, respectively, were in fact royalties deductible under the provisions of section 23 (a) of the Internal Revenue Code, and ...
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