TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax for 1977 and 1978:
Year Deficiency 1977 ..................... $230,031 1978 ..................... 82,525
After concessions, we must determine whether petitioners are entitled to various deductions and credits claimed in connection with Sydney Baron's purchase of the U.S. and Canadian rights...
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