- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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