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MILBERG v. COMMISSIONER

Docket No. 621-68.

54 T.C. 1562 (1970)

JACQUES R. MILBERG AND ELAINE K. MILBERG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 30, 1970.

Attorney(s) appearing for the Case

Lawrence Milberg, for the petitioners.

Agatha L. Vorsanger, for the respondent.

FAY, Judge:

Respondent determined deficiencies in petitioners' income taxes of $7,569.94 and $8,556.31 for the taxable years 1963 and 1964, respectively.

In Jacques R. Milberg, 52 T.C. 315 (1969), this Court held that, for the taxable year 1962, petitioner had not transferred all substantial rights to a patent pursuant to section 1235,1 and therefore that royalties resulting from the...

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