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VAN DALE CORPORATION v. COMMISSIONER

Docket Nos. 1097-70, 1109-70.

59 T.C. 390 (1972)

VAN DALE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. VAN DALE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1972.

Attorney(s) appearing for the Case

Robert J. Johnson and John W. Windhorst, Jr., for the petitioners.

Jay B. Kelly, for the respondent.

IRWIN, Judge:

These cases were consolidated for trial and decision. Respondent determined a deficiency of $199 in the income tax of petitioner Van Dale Corp. for the taxable year ended April 30, 1967, in docket No. 1097-70. The issue for determination in this case is whether respondent correctly allocated royalty income received by North Star Patents, Inc., to petitioner under either section 4821 or section 61.

In docket...

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