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BERGER CHEVROLET, INC. v. COMMISSIONER

Docket Nos. 5882-96, 16336-96.

74 T.C.M. 1113 (1997)

T.C. Memo. 1997-499

Berger Chevrolet, Inc. v. Commissioner. Timothy M. & Helen L. Petty v. Commissioner.

United States Tax Court.

Filed November 6, 1997.

Attorney(s) appearing for the Case

Ray Foresman, for the petitioners. Elizabeth Patino, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' Federal income taxes as follows:

Petitioner                         Year   Deficiency

Berger Chevrolet, Inc. .........   1990     $13,087
Timothy and Helen Petty ........   1987      21,908

The issue is whether, on the facts set forth hereinafter, commissions paid to a car dealership's finance and insurance manager for...

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