Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code and Rule 180 et seq.
Respondent determined a deficiency in petitioners' Federal income tax for 1985 in the amount of $1,386. The sole issue for decision is whether certain advances to petitioner Albert McIsaac in prior years and repayable out of future commissions constituted...
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