Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Taxable Year Deficiency 1974 $19,023 1975 30,057 1976 14,644
The sole issue for decision is whether payments made to petitioner, Richard Herrick, by Farmers Insurance Group in exchange for cancellation of petitioner's contract...
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