Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in petitioners' income tax for the years and in the amounts as follows:
1954............ $986.47 1955............ 804.68 1956............ 762.88
The sole issue presented for our decision is the correctness of the respondent's action in determining that certain royalty payments made to petitioner during the years in issue...
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