MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $22,011 deficiency and additions to tax under sections 6651(a)(1) and (2) and 6654 in the amounts of $4,883, $2,930, and $1,165, respectively, with respect to petitioner's 1996 Federal income tax.
The sole issue in dispute concerns the amount of commission income petitioner must report as taxable income in 1996.
FINDINGS OF FACT<...
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