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PROFESSIONAL INSURANCE AGENTS OF WASHINGTON v. COMMISSIONER

Docket No. 8949-83.

53 T.C.M. 9 (1987)

T.C. Memo. 1987-68

Professional Insurance Agents of Washington v. Commissioner.

United States Tax Court.

Filed February 3, 1987.

Attorney(s) appearing for the Case

George A. Simpson, 5301 Juxon Pl., Springfield, Va., and George J. Rabil, for the petitioner. Cynthia J. Mattson, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

  Taxable Year Ended                   Deficiency

  September 30, 1978 ..............     $2,983
  September 30, 1979 ..............     $2,250

After concessions, the sole issue for decision is whether insurance administrative fees received by petitioner, a business league of insurance...

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