Charles L. Fields and Barbara S. Fields - Page 1

                                 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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