James J. and Sandra A. Gales - Page 1

                                  T.C. Memo. 1999-27                                   

                               UNITED STATES TAX COURT                                 

                    JAMES J. AND SANDRA A. GALES, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 4345-97.                  Filed February 1, 1999.            

                    P received advance commissions on insurance                        
               written by him.  The advance commissions were repayable                 
               on demand, and bore interest, and repayment was secured                 
               by earned commissions.  Such advance commissions were                   
               shown as income on Forms 1099-MISC, Miscellaneous                       
               Income, received by P.  Held, Ps have proven the amount                 
               of advance commissions.  Held, further, the advance                     
               commissions were received as loans and are not gross                    

               S. Thomas Ullman, for petitioners.                                      
               Thomas E. Ritter, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         

               HALPERN, Judge:  By notice of deficiency dated December 6,              
          1996, respondent determined deficiencies in petitioners' Federal             

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