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POSTER v. COMMISSIONER

Docket No. 40925-84.

55 T.C.M. 117 (1988)

T.C. Memo. 1988-57

Herbert Poster and Susan Poster v. Commissioner.

United States Tax Court.

Filed February 18, 1988.

Attorney(s) appearing for the Case

William J. Werner, Fort Lee, N.J., for the petitioners. Francis J. Strapp, Jr., for the respondent.

Memorandum Opinion

WRIGHT, Judge:

By a notice of deficiency dated September 19, 1984, respondent determined a deficiency of $69,082 in petitioners' 1979 Federal income tax. This case is before the Court on respondent's motion for partial summary judgment under Rule 1211 on the single issue of whether petitioners may deduct an alleged advanced minimum royalty payment.

Herbert and Susan Poster, petitioners, were residents...

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