Eric A. and Jane C. Lanigan - Page 9

                                                 - 9 -                                                    
                  Source                                      Amount                                      
                  Provident Mutual                            $10,581                                     
                  Gordon Anthony                              5,047                                       
                  Stuart and Florence Bellus                  199                                         
                  Variable Investment Plans, NEC              888                                         
                                           Total              $16,715                                     
            In the taxable year 1991, petitioners received the following                                  
            nonemployee compensation that was omitted from their tax return                               
            for that year.                                                                                
                  Source                                      Amount                                      
                  Ernest Beccaris                             $14,751                                     
                  Anthony Mastrangelo                         118                                         
                  North American Co.                          8,670                                       
                  Life U.S.A. Insurance                       7,999                                       
                  American Association for                                                                
                  Secured Planning                            1,400                                       
                  Fourth Financial Services                   24,780                                      
                  Rex Huffman                                 2,324                                       
                  Provident Life                              1,020                                       
                  Palumbo Partners                            2,136                                       
                  Pan American Life                           4,747                                       
                  Security Life                               8,314                                       
                                           Total              $76,259                                     

                  Of these amounts of unreported income for 1991, respondent                              
            now concedes that $4,335 of the $8,670 from North American                                    
            Company and $12,518.45 of the $24,780 from Fourth Financial                                   
            Services were "assigned" to other persons; i.e., were paid as                                 
            commissions to those other persons and hence are deductible by                                
            petitioner as business expenses.4  Petitioners have now conceded                              

            4In other words, while the assigned amounts are includable                                    
            in petitioner's income, he is entitled to a business expense                                  
            deduction in an equal amount.  See Helvering v. Eubank, 311 U.S.                              
            122 (1940); Bird v. Commissioner, T.C. Memo. 1962-74.                                         





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