The intention of the German parent of the taxpayer in negotiating a contract for the cancellation of a franchise prior to the incorporation of the...
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A payment made by a prospective franchisee to procure the surrender of a prior franchise so that it could obtain a franchise, was a proper element...
The cost to the taxpayer (namely, the sum of $108,000 paid by it to terminate a previous franchise arrangment) of obtaining a contractual right to...
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