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Recorded on Conceded by
Amount YOC Books As Benefit to Elvin Petitioners
$15,136 Not deducted Repairs on Elvin's No
residence
Travel Awards
In 1983 and 1985, Elvin received travel awards from General
Motors relating to the successful operation and profitability of
YOC. In 1983, Elvin received a trip to Germany at a cost of
$4,361. In 1985, Elvin and his wife received a trip to France
and Switzerland at a cost of $10,087.
For both 1983 and 1985, Elvin did not provide his income tax
return preparer any information regarding these travel awards,
and no amount with respect to these travel awards was reported as
income on Elvin's 1983 and 1985 Federal income tax returns.
On audit, respondent determined that costs of $4,361 in 1983
and $10,087 in 1985 relating to these travel awards represented
income to Elvin under section 74(a).
Elvin's Brain Tumor
On June 19, 1987, Elvin was diagnosed as having a tumor in
the frontal lobe of his brain. The frontal lobe constitutes the
area of the brain responsible for, among other things, the
ability to perform executive functions and complex tasks, the
ability to plan, remember, and carry out logical sequences of
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