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HARMON v. COMMISSIONER

Docket No. 4686-83.

51 T.C.M. 1243 (1986)

T.C. Memo. 1986-251

Stephen Harmon v. Commissioner.

United States Tax Court.

Filed June 19, 1986.

Attorney(s) appearing for the Case

Michael J. Sheber, for the petitioner, 445 Park Ave., New York, New York. Michael Goldbas, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

Respondent determined a deficiency of $25,726.19 in petitioner's 1977 Federal income tax. This case is before the Court on respondent's motion for partial summary judgment under Rule 1211 on the issue of whether petitioner may deduct an alleged advanced minimum royalty payment.

Petitioner Stephen Harmon resided in Miami Beach, Florida, when the petition was filed herein.

The Huron...

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