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BROWN v. COMMISSIONER

Docket No. 34462-83.

50 T.C.M. 1418 (1985)

T.C. Memo. 1985-564

Jack Brown and Clara Brown v. Commissioner.

United States Tax Court.

Filed November 18, 1985.

Attorney(s) appearing for the Case

Remo Tinti, for the petitioners. Victoria Wilson Fernandez, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

Respondent determined a deficiency of $55,130 in petitioners' 1978 Federal income tax. This case is before the Court on respondent's motion for summary judgment under Rule 1211 on the issue of whether petitioners may deduct an alleged advanced minimum royalty payment and on respondent's motion to impose damages under section 6673.

Petitioners Jack and Clara Brown resided in Whitestone...

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