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PROFESSIONAL INSURANCE AGENTS v. COMMISSIONER

Docket No. 11748-78.

78 T.C. 246 (1982)

PROFESSIONAL INSURANCE AGENTS OF MICHIGAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 17, 1982.

Attorney(s) appearing for the Case

Bruce B. Hart, for the petitioner.

William F. Garrow, for the respondent.

DAWSON, Judge:

Respondent determined the following deficiencies in petitioner's Federal income taxes:

       TYE Sept. 30—                      Deficiency

        1974 .........................     $17,200.57
        1975 .........................      41,692.72
        1976 .........................      24,134.69

After concessions, the issues for decision are whether...

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