KÖRNER, Judge:
Respondent determined a deficiency in petitioner's individual income tax for the calendar year 1975 in the amount of $20,685.61. After concessions, the sole issue which we are called upon to decide is whether certain payments received by petitioner in the year 1975 constitute "royalties," within the meaning of the applicable income tax treaty between the Federal Republic of Germany and the United States, and are therefore exempt from tax...
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