Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined a deficiency of $33,892 in petitioners' 1977 Federal income tax. The issues presented for consideration are: (1) Whether petitioners are entitled to deduct certain claimed "advanced minimum royalties" under section 1.612-3(b)(3), Income Tax Regs., and (2) whether damages should be awarded under section 6673.
Findings of Fact
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