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or entity in fact controls the earning of the income rather than
the question of who ultimately receives the income. Wesenberg v.
Commissioner, 69 T.C. 1005 (1978); American Sav. Bank v.
Commissioner, 56 T.C. 828 (1971). The Supreme Court held in
Helvering v. Horst, 311 U.S. 112, 117 (1940), that the power to
dispose of income is the equivalent of ownership of it.
Therefore, exercising power to procure payment of income to
another is in fact the realization of the income by him who
directed the payment. In the case herein, it is undisputed that
petitioner performed services for Dr. Chan. The fact that
petitioner did not need the money Dr. Chan paid for lessons in
order to support his family does not negate the fact that money
earned for the performance of services is income. Sec. 61(a)(1).
Petitioner, however, contends that he not only did not receive
payment for his services, but he also received no benefit from
the payments to Yao Min Ting, Ting Yao Min, or Tang Chiang Ting.
The earner of income is not relieved of his tax liability
merely because he chooses not to receive or enjoy the income for
himself. Lucas v. Earl, supra. Petitioner performed the
services for which Dr. Chan paid. Petitioner cannot avoid taxa-
tion simply by requesting that payment be made in the name of
other persons. We find that all of the amounts paid by Shanghai
Clinic to Yao Min Ting, Ting Yao Min, and Tang Chiang Ting, as
well as a check from 1990 reimbursing Dr. Chan for money paid to
petitioner, were income to petitioners. Petitioners have pre-
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