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GALES v. COMMISSIONER

Docket No. 4345-97.

77 T.C.M. 1316 (1999)

T.C. Memo. 1999-27

James J. and Sandra A. Gales v. Commissioner.

United States Tax Court.

Filed February 1, 1999.

Attorney(s) appearing for the Case

S. Thomas Ullman, for the petitioners. Thomas E. Ritter, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

By notice of deficiency dated December 6, 1996, respondent determined deficiencies in petitioners' Federal income taxes for 1992 and 1993 of $10,778 and $56,165, respectively. Petitioners assign error to some of respondent's determinations on the basis that respondent erred in treating certain advance commissions as compensation rather than as loans. Petitioners also claim that petitioner Sandra A....

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