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HOLLAND v. COMMISSIONER

Docket No. 14787-81.

51 T.C.M. 164 (1985)

T.C. Memo. 1985-626

Brian Holland v. Commissioner.

United States Tax Court.

Filed December 26, 1985.

Attorney(s) appearing for the Case

Hallison H. Young, 3770 City National Bank Bldg., Detroit, Mich., for the petitioner. Beth Williams and Arthur L. Skaar, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency of $34,679 in petitioner's 1974 Federal tax return. After concessions,1 the issues for determination are:

(1) Whether a portion of petitioner's accrued royalties were used to purchase master recordings in 1974 and, therefore, must be reported as income in that year;

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