United States Tax Court.
Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $34,435.60 in income taxes of the petitioner for 1948. The only issue is whether the amount of $89,164.78, deducted by the petitioner as an ordinary and necessary expense, representing royalties accrued by the petitioner for 1948 payable to Fred and Isidore Himmel, were not deductible because unreasonably large in amount.
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