ALEX v. COMMISSIONER

Docket No. 10458-75.

70 T.C. 322 (1978)

JAMES ALEX AND BETTY JEAN ALEX, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 24, 1978.


Attorney(s) appearing for the Case

Barney B. Shiotani, for the petitioners.

Hector C. Perez, for the respondent.


TANNENWALD, Judge:

Respondent determined a deficiency of $38,444 in petitioners' Federal income tax for the year 1972. As a result of concessions by the parties, the sole issue is whether rebates and discounts paid by James Alex to purchasers of life insurance policies reduced his commissions and thereby are properly excludable from petitioners' gross income.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly...

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