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HERNANDEZ v. COMMISSIONER

Docket No. 9459-77.

38 T.C.M. 1068 (1979)

T.C. Memo. 1979-272

Humberto Hernandez and Ileana Hernandez v. Commissioner.

United States Tax Court.

Filed July 23, 1979.

Attorney(s) appearing for the Case

Donatello M. Rosignoli, for the petitioners. Hans G. Tanzler, III, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' joint Federal income tax as follows:

  Year                Deficiency

  1973 ............. $ 2,539.41
  1974 .............  11,109.13

After concessions, the sole issue for decision is whether certain subagent commission expenses paid by a United States citizen in operating a Costa Rican insurance business were properly disallowed as a deduction...

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