- 12 -
The following commission checks were deposited into the C account
during 1980 and 1981:
Date of Payment Barrels Commission Amount Date Shipped
Apr. 30, 1980 404,968 .30/brl $121,490 3/30/80
May 12, 1980 457,680 .30/brl 137,304 4/15/80
May 14, 1980 441,837 .30/brl 132,551 4/22/80
June 20, 1980 514,339 .30/brl 154,302 5/13/80
Sept. 17, 1980 546,934 .25/brl 136,733 8/20/80
Oct. 9, 1980 508,128 .25/brl 127,032 9/11/80
Nov. 10, 1980 476,470 .25/brl 119,117 10/11/80
Dec. 11, 1980 516,144 .25/brl 129,036 11/11/80
Jan. 12, 1981 515,671 .25/brl 128,918 12/12/80
Feb. 2, 1981 536,050 .27/brl 144,734 1/3/81
Mar. 6, 1981 515,455 .27/brl 139,173 2/4/81
Apr. 2, 1981 517,336 .27/brl 139,681 3/3/81
1,610,071
Of the total commissions of $1,610,071, BarSon ultimately
received $232,540 and $245,500 of this amount in 1980 and 1981,
respectively, for a total of $478,040. Approximately $265,000 of
this $478,040 amount was reported on BarSon's 1980 tax return.13
BarSon never reported any other commissions as income on a
Federal income tax return. The commissions that respondent seeks
to attribute to petitioners have been reduced by the $478,040 of
commissions reported by BarSon.14 Respondent gave petitioners
credit for $245,500 paid to BarSon in its 1981 taxable year,
although BarSon never included this amount in its gross income.
13 This return reports that BarSon had $571,790 of total
income and $57,483 of taxable income.
14 Respondent further reduced the commissions reportable by
petitioners for 1980 and 1981 by $337,921 and $124,985,
respectively. See supra note 2.
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