BRIGHT, Circuit Judge.
In 1965, taxpayer-appellant, Leisure Dynamics, Inc. (formerly Lakeside Industries, Inc.), a toy manufacturer, paid $102,676.45, for the right to manufacture dolls in the likeness of animated doll characters known as "Gumby" and "Gumby's Pal, Pokey" (a horse) that have appeared on television cartoon series entitled "The Adventures of Gumby." Taxpayer considered this sum of money a royalty payment and therefore deductible from gross income. The...
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