Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $2,016,773 for 1982 and $2,223,929 for 1983.
Petitioner bought the Life Savers trademarks in 1981 as part of its purchase of the Life Savers business from Squibb, Inc. (Squibb). After concessions, the sole issue for decision is whether petitioner's payments to Squibb for the Life Savers trademarks are deductible under section...
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