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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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