OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $354,228.07 and $2,030,062.96 for the taxable years ended October 31, 1972, and October 31, 1973, respectively. Petitioner has conceded the correctness of some of the adjustments respondent made in the notice of deficiency, leaving for our decision only the proper amount of commission income of petitioner's domestic international sales corporation...
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