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FREDKIN v. C.I.R.

No. 88-1039.

870 F.2d 801 (1989)

Norman J. FREDKIN and Annie G. Fredkin, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided March 30, 1989.

Attorney(s) appearing for the Case

Donald Jay Pols with whom Beilis & Pols, P.C., New York City, was on brief, for petitioners.

David M. Moore, Tax Div., Dept. of Justice, with whom William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen and David I. Pincus, Tax Div., Dept. of Justice, Washington, D.C., were on brief, for respondent.

Before BOWNES and BREYER, Circuit Judges, and CAFFREY, Senior District Judge.

BREYER, Circuit Judge.

In 1977 taxpayers Norman and Annie Fredkin subleased the right to mine diamonds in Namibia from a Dutch company called Imperial Finance, N.V. ("Imperial"). Their sublease required them to pay Imperial a minimum of $50,000 each year whether or not anyone mined any diamonds. The sublease referred to this payment as a "minimum royalty." And, the sublease allowed the Fredkins to deduct this advance "minimum royalty" payment from the royalties they...

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