Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $18,335, $45,914 and $70,305 for the taxable years 1973, 1974 and 1975, respectively. Due to concessions by the parties, the issues remaining for decision are (1) whether payments made by petitioners (life insurance agents) to satisfy premium obligations of purchasers of life insurance policies may be applied to reduce petitioners...
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