Adnan Al Kaissy - Page 19

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            prorating it among the wrestlers.  As the owner of MBWC                                    
            testified, this split the cost of airline transportation between                           
            the club and the wrestlers.  When the wrestlers had paid for                               
            their own transportation, there was no deduction from gross                                
            receipts for transportation prior to the split between the club                            
            and the wrestlers.  Therefore, the wrestlers each received more                            
            from the receipts of the show than they did after the club paid                            
            the airline ticket costs or chartered plane costs and deducted                             
            it, as the wrestlers say, "off the top" of the take before its                             
            division between the wrestlers and the club.  In the economic                              
            sense, the wrestlers paid a part of their own airline                                      
            transportation by receiving less for wrestling at performances                             
            when they went by airplane than they would have received had the                           
            club not furnished them with the airline tickets.  Petitioner's                            
            return preparer was convinced that if the club had paid out the                            
            amount for the airline tickets as the club manager testified, the                          
            amount should have been shown on the Forms 1099 furnished to the                           
            wrestlers as part of payment in money or in kind to the wrestlers                          
            for the year.  Whether or not she is correct in her conclusion                             
            that the amount paid by MBWC for air fare should have been                                 
            included on the Forms 1099, there is certainly much to be said                             
            for her position that it should have been.  Many people do not                             
            understand the concept that a deduction cannot generally be taken                          
            for something where an equivalent amount has not been included in                          

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Last modified: May 25, 2011