Charles L. Fields and Barbara S. Fields - Page 6

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          companies to build in Africa.4  Dr. Young and petitioner are                
          BarSon's president and secretary, respectively, and they each own           
          50 percent of its stock.  BarSon is a cash method taxpayer, and             
          its taxable year ends on March 31.                                          
               On November 19, 1979, BarSon and Ashland Oil, Inc.                     
          (Ashland), entered a written agreement under which BarSon's                 
          managing directors (petitioner and Dr. Young) or other key                  
          employees would advise Ashland on starting business abroad                  
          (including the requirements for purchasing crude oil in foreign             
          countries) in exchange for a daily fee of $750 plus expenses.5              
          The agreement did not contain a provision for Ashland to pay                
          BarSon commissions on the actual purchase of oil by Ashland.                
          Petitioner and Dr. Young, on behalf of themselves, entered into a           
          separate oral agreement with Ashland under which Ashland would              
          pay commissions to petitioner and Dr. Young for any oil purchased           
          as a result of their efforts.  Petitioners have never reported              
          any income on their personal income tax returns for commissions             



               4 Dr. Young is the brother of Andrew Young, the U.S.                   
          ambassador to the United Nations during the Carter                          
          administration.  The occurrences described below began at or                
          about the time when Andrew Young led an official U.S. trade                 
          delegation (with petitioner and Dr. Young) to Africa to discuss             
          oil and other matters.                                                      
               5 BarSon and Ashland amended this agreement on Feb. 1, 1981,           
          to increase the daily rate to $1,250, with a minimum of $15,625             
          per month.  From 1979 until 1981, Ashland paid BarSon at least              
          $713,765 under this agreement.  These payments were deposited               
          into BarSon's bank accounts.                                                




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