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DEFFENDALL v. UNITED STATES

Civ. No. 73-877.

386 F.Supp. 509 (1974)

Donald E. DEFFENDALL and Bettle Deffendall, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Oregon.

October 8, 1974.

Attorney(s) appearing for the Case

Warde H. Erwin, Erwin, Lamb & Erwin, Portland, Or., for plaintiffs.

Sidney I. Lezak, U. S. Atty., Portland, Or., James N. Flaherty, Tax Div., Dept. of Justice, Washington, D. C., for defendant.

OPINION

BURNS, District Judge.

Plaintiff in this tax refund suit has a license from Dale Carnegie and Associates, Inc. that permits him to conduct the well known Dale Carnegie Courses. In the tax years at issue, he paid substantial sums, calculated as a percentage of gross tuition, to the person who held the license before him and assigned it to him. When deduction of these sums was disallowed and deficiency...

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