OPINION
DAWSON, Judge:
Respondent determined a deficiency in income tax against petitioners for the years 1962 and 1963 in the amounts of $1,263.84 and $2,065.92, respectively.
The issues for decision are whether amounts paid as "commissions" by petitioner Larry D. Hibler to G. O. Walker, pursuant to an agreement for the purchase of certain properties of the Walker Insurance Agency, are includable in petitioner's gross income and, if so, whether...
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