SHOTTS v. COMMISSIONER

Docket No. 22924-88.

60 T.C.M. 1480 (1990)

T.C. Memo. 1990-641

Arthur E. and Nellie L. Shotts v. Commissioner.

United States Tax Court.

Filed December 20, 1990.


Attorney(s) appearing for the Case

Charles N. Woodward, 6303 Waterford Blvd., Oklahoma City, Okla., for the petitioners. Juandell D. Glass and Bruce K. Meneely, for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

The sole issue for decision is whether certain amounts received by petitioner from Barnes Brokerage Co., Inc. (Barnes Brokerage), in 1983 were commission income. References to petitioner in the singular are to Arthur E. Shotts.

Respondent determined a deficiency for petitioners for taxable year 1983 in the amount of $43,622.94. No additions to tax were determined.

Petitioner was a commodities...

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