Memorandum Findings of Fact and Opinion
COLVIN, Judge:
The sole issue for decision is whether certain amounts received by petitioner from Barnes Brokerage Co., Inc. (Barnes Brokerage), in 1983 were commission income. References to petitioner in the singular are to Arthur E. Shotts.
Respondent determined a deficiency for petitioners for taxable year 1983 in the amount of $43,622.94. No additions to tax were determined.
Petitioner was a commodities...
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