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such payment that respondent concedes petitioner may deduct.1 We
hold that it is not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time of the filing of the petition in this case,
petitioner’s principal place of business was in Philadelphia,
Pennsylvania.
In May 1999, the name “Chickie’s and Pete’s” was registered
with the United States Patent and Trademark Office (U.S. Patent
and Trademark office).2 On or about September 1, 1999, peti-
tioner began operating a bar/restaurant under that name on
Roosevelt Avenue in Philadelphia, Pennsylvania (Philadelphia).
At all relevant times, Peter Ciarrocchi, Jr. (Mr. Ciarrocchi),
was petitioner’s sole stockholder and officer, as well as the
sole stockholder and officer of 4010, Inc., which operated a
bar/restaurant under the name “Chickie’s and Pete’s” on Robbins
Avenue in Philadelphia.
On April 12, 1999, 4010, Inc., and Ogden Entertainment, Inc.
(Ogden), which was operating food and beverage concessions at
Veterans Stadium in Philadelphia (Ogden’s Veterans Stadium
1Respondent concedes that petitioner may deduct $441,210 of
the $902,476 payment in question.
2The application to register the name “Chickie’s and Pete’s”
was submitted to the U.S. Patent and Trademark office on Apr. 17,
1998.
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