Charles L. Fields and Barbara S. Fields - Page 12

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          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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