Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner's Federal income tax for the taxable years 1976 and 1977 in the amounts of $1,676.66 and $2,215.94, respectively. After concessions, the issue for decision is whether fees received by petitioner for performing various services in connection with errors and omissions insurance, which petitioner helped make available to its members, constituted unrelated...
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