Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for taxable years 1968, 1969 and 1970 as follows:
Year Deficiency 1968 ..................... $ 208,673 1969 ..................... 19,789,652 1970 ..................... 1,406,012
After concessions, the issue presented is whether unpaid commissions to...
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