The Commissioner determined deficiencies of $36,657.57 and $16,507.27 in petitioners' income tax for the calendar years 1961 and 1962 respectively. After concessions, the following issues remain for decision: (1) Whether certain commissions received by petitioner Sol Diamond in 1961 must be included in petitioners' gross income for that year under section 61, I.R.C. 1954, and if so, whether purported "consultants fees" paid by him in respect of such commissions during that...
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