T.C. Memo. 1996-425
UNITED STATES TAX COURT
CHARLES L. FIELDS AND BARBARA S. FIELDS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26636-87. Filed September 19, 1996.
A, a corporation, agreed with P and Y to pay them
commissions on any oil that it purchased in foreign
countries as a result of their efforts. P and Y
organized a Bermudan corporation, to which they
directed the payment of all the commissions. Held:
The commissions attributable to P's services are
taxable to him under the assignment of income doctrine.
Held, further: Ps failed to recognize dividend income
in the amounts set forth by R. Held, further: Ps
failed to recognize interest income in the amounts set
forth by R. Held, further: P is liable for additions
to tax for fraud, and the 3-year period of limitation
under sec. 6501(a), I.R.C., does not bar the assessment
and collection of tax for any of the subject years.
Held, further: P's wife is not an innocent spouse
under sec. 6013(e), I.R.C.
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