MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1988 and 1989 in the amounts of $6,335 and $6,250, respectively.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision whether insurance commissions on insurance policies written by petitioner under a contract between petitioner and an insurance...
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