WIGGINS, Circuit Judge:
William P. Cheng appeals from the Tax Court's grant of partial summary judgment in favor of the Commissioner of the Internal Revenue Service (Commissioner) upholding the Commissioner's determination that Cheng's minimum royalty payments of $20,000 in 1977 and $60,000 in 1978 for unmined diamonds were not deductible under Treas.Reg. § 1.612-3(b)(3) (as amended in 1977). We conclude that we lack jurisdiction for want of an appealable final...
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