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MADDRIX v. C.I.R.

No. 85-3173.

780 F.2d 946 (1986)

James MADDRIX and Alice Maddrix, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

January 22, 1986.

Attorney(s) appearing for the Case

Elliot I. Miller, Pawling, N.Y., for petitioners-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Tax Div., David E. Carmack, Francis M. Allegra, Attys., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before RONEY and ANDERSON, Circuit Judges, and MORGAN, Senior Circuit Judge.

ANDERSON, Circuit Judge:

James Maddrix and Alice Maddrix ("Taxpayer")1 appeal from a decision of the Tax Court disallowing, inter alia, certain advanced minimum royalty deductions and determining a $74,069.51 deficiency in their 1977 joint federal income tax return. This case presents a question of first impression concerning the proper application of 26 C.F.R. § 1.612-3(b)(3) (1985), which governs the deductibility of advanced...

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