Long v. United States

OPINION

NETTESHEIM, Judge.

The question to be resolved is whether a limited partnership can take a current-year deduction in the year liability is accrued for payment of advanced royalties pursuant to what they contend is a minimum royalty provision of a mineral sublease. Defendant moved, over plaintiffs’ opposition, for summary judgment, although plaintiffs take the position that no genuine issue of material fact impedes granting summary judgment in their favor.

FACTS

The following facts that are not a matter of statute, regulation, case law, or agency interpretation are undisputed. A.B. Long,…