It is not disputed that more than 80% of petitioner's gross income was derived from his personal services and that capital was not a material income producing factor. Consequently, the sole issue is whether petitioner was engaged "in the practice of any * * * profession". Petitioner used the terms "commercial artist" and "commercial illustrator" interchangeably in describing his occupation. He operated as a "free lance", being paid for each advertisement that he was commissioned...
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