MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court under section 6226 to readjust partnership items adjusted by respondent. Following the parties' concessions, we must decide whether Vision Information Services, L.L.C. (Vision), sold or instead licensed certain intellectual property to Twentieth Century Fox (FoxVideo). Respondent determined and argues that Vision licensed the property to FoxVideo and, hence, that payments...
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