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$20,000. The $40,500 balance owed to petitioner was credited
against the $40,500 debt petitioner owed to Mr. Riccardi in 1996.
To conclude, we hold that petitioner realized $60,500 of income as
commission income in 1996.
To reflect the foregoing, and petitioner’s concessions,
Decision will be entered
for respondent.
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Last modified: May 25, 2011