James Leslie Clark Valarian - Page 5

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          allowance of the deductions here in dispute, but upon whether he            
          should be entitled to exclude from income earnings over which, in           
          his view, he had no discretionary control.  To the extent we                
          understand petitioner's arguments, we find them to have no merit.           
          Suffice it to say that similar arguments have been previously               
          rejected by the Court.  See Knight v. Commissioner, T.C. Memo.              
          1992-710, affd. without published opinion 29 F.3d 632 (9th Cir.             
          1994).                                                                      
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered for respondent.                  



























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