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benefit argument is not supported by any evidence that the
automobiles were intended to be treated as compensation.
Therefore, petitioner is not entitled to deduct the claimed
automobile expenses as fringe benefit payments to his employees.
II. Issues 1,2,3, and 6--Commission and Miscellaneous Income
Turning now to the substantive issues, we first address the
issue of commission income. Under the "assignment of income"
doctrine, it is a fundamental principle of income tax law that
income must be taxed to the person who earned it. United States
v. Basye, 410 U.S. 441, 449-451 (1973). Under this principle, we
must decide on this record who "earned" the commission income
received from the various companies involved with petitioner
during the years in question. In deciding this issue, we attempt
to put some substance into the concept of earning income. On one
hand, we recognize that because "the true earner cannot always be
identified simply by pointing 'to the one actually turning the
spade or dribbling the ball,' this Court has applied a more
refined test--that of who controls the earning of the income."
Fritschle v. Commissioner, 79 T.C. 152, 155 (1982).
But, on the other hand, "the existence of a corporation
formed for a valid business purpose should not be nullified
merely because the shareholders are actively interested in
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