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under section 162(a)(3) constitutes compensation for services
rendered that is deductible under section 162(a)(1).
Based upon our examination of the entire record before us,
we find that petitioner has failed to carry its burden of estab-
lishing that it is entitled to deduct for the year at issue the
portion of the $902,476 payment under petitioner’s license
agreement in excess of the amount that respondent concedes.
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing and the concession of respondent,
Decision will be entered
under Rule 155.
[Reporter’s Note: This report was modified by Order dated Nov. 7, 2005.]
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