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VASTOLA v. COMMISSIONER

Docket No. 2247-84.

84 T.C. 969 (1985)

DOROTHY VASTOLA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 21, 1985.

Attorney(s) appearing for the Case

William J. Werner and Richard L. Gold, for the petitioner.

Francis J. Strapp, Jr., for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for taxable years 1977 and 1978 of $83,164.63 and $27,267.85, respectively. The case is before this Court on respondent's motion for partial summary judgment under Rule 1211 on the issue of whether petitioner may deduct her claimed losses for the years in issue to the extent they resulted from alleged advanced minimum royalty...

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