Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $261,416 and $336,349 in petitioners' Federal income taxes for 1977 and 1978, respectively. Petitioners concede that they are not entitled to the deductions claimed on their returns for advanced minimum royalties. They claim, however, that they are entitled to enforce an agreement whereby they would be allowed to deduct payments made in each year in the sum of $135...
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