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MIYAGAWA v. COMMISSIONER

Docket No. 4644-83.

51 T.C.M. 284 (1986)

T.C. Memo. 1986-19

Daisho D. Miyagawa and Emiko A. Miyagawa v. Commissioner.

United States Tax Court.

Filed January 15, 1986.

Attorney(s) appearing for the Case

John Patrick Kelly, 3659 Adams Avenue, San Diego, Calif., for the petitioners. John O. Kent, for the respondent.

Memorandum Opinion

FAY, Judge:

With respect to petitioners' 1977 Federal income tax, respondent determined a deficiency of $15,814.00 and an addition to tax of $790.70 under section 6653(a).1

The issues are (1) whether petitioners may deduct certain claimed "advanced minimum royalties" under section 1.612-3(b)(3), Income Tax Regs., (2) whether petitioners are liable for an addition to tax under section 6653(a), and (3...

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