PREGERSON, Circuit Judge:
Robert E. Milligan ("Milligan") appeals the tax court's order and decision upholding the Commissioner of Internal Revenue's determination of a deficiency in Milligan's federal income tax for the taxable year 1987 in the amount of $3,076.00. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We reverse.
BACKGROUND
On April 12, 1949, Appellant Milligan began working as an exclusive insurance agent, on an independent contractor...
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