Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1946 in the amount of $2,807.12. The sole issue is whether petitioner was correct in treating commissions which he received during 1946 for the sale of a business as taxable under section 107 (a) of the Internal Revenue Code.
Findings of Fact
Petitioner is an individual residing in Hamilton, New York. His income tax...
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