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ESTATE OF BLAY v. COMMISSIONER

Docket Nos. 17811-80, 17812-80, 17813-80, 17814-80, 17818-80, 17820-80, 17821-80, 17823-80, 21229-80, 21230-80, 12537-81, 12538-81, 12539-81, 12540-81, 14401-81, 15270-81, 15272-81, 15837-81.

48 T.C.M. 1463 (1984)

T.C. Memo. 1984-565

Estate of Charles P. Blay, Deceased, Winifred I. Blay, Administratrix, and Winifred I. Blay, et al. v. Commissioner.

United States Tax Court.

Filed October 23, 1984.

Attorney(s) appearing for the Case

Elliot I. Miller, 745 Fifth Ave., New York, N.Y., for the petitioners. Theodore J. Keltnick and Kendall C. Jones, for the respondent.

Memorandum Opinion

STERRETT, Judge:

These consolidated cases are before the Court on petitioners' motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.2 The issue raised by the motion is whether certain lump-sum amounts paid3 by petitioners in the form of cash and nonrecourse promissory notes constitutes "advanced minimum royalties" within the contemplation...

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