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ROTH v. COMMISSIONER

Docket Nos. 3750-82, 16071-83.

51 T.C.M. 287 (1986)

T.C. Memo. 1986-20

Robert L. Roth and Alberta Mae Roth v. Commissioner.

United States Tax Court.

Filed January 15, 1986.

Attorney(s) appearing for the Case

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

Memorandum Opinion

FAY, Judge:

Respondent determined deficiencies of $14,734 and $26,646 in petitioners' 1977 and 1978 Federal income tax, respectively.

After concessions, the issues in these consolidated cases are (1) whether petitioners may deduct in 1977 and 1978 certain claimed "advanced minimum royalties" under section 1.612-3(b)(3), Income Tax Regs., and (2) whether damages should be awarded under...

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