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GAUNTT v. COMMISSIONER

Docket Nos. 1704-81, 6332-81, 25642-81, 29502-81, 2275-82.

82 T.C. 96 (1984)

LLOYD E. GAUNTT, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 12, 1984.

Attorney(s) appearing for the Case

George Mac Vogelei and William K. Hogan, for the petitioners.

Claire Priestley-Cady, for the respondent.

OPINION

SIMPSON, Judge:

This matter is before the Court on the Commissioner's motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.2 The issues raised by the motion are: (1) Whether the Commissioner properly applied the amended section 1.612-3, Income Tax Regs., to disallow certain partnership loss deductions for advanced royalties...

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