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assuring the success of the corporation." Ross Glove Co. v.
Commissioner, 60 T.C. 569, 591 (1973). As these statements
demonstrate, particularly in cases involving closely held
corporations, such as is present here, or one-man personal
service corporations, there is a tension between the doctrine
prohibiting the assignment of income and the recognition of a
corporate business form as a separate legal entity from its
owners. Moline Properties, Inc. v. Commissioner, 319 U.S. 436,
438-439 (1943). Here too, in resolving the issue of whether the
individual or his wholly owned corporation is taxable on income
earned through the performance of personal services, the primary
focus is upon whether the individual or the corporation controls
the earning of the income. Bagley v. Commissioner, 85 T.C. 663,
675 (1985), affd. 806 F.2d 169 (8th Cir. 1986); Johnson v.
Commissioner, 78 T.C. 882, 890-891 (1982), affd. without
published opinion 734 F.2d 20 (9th Cir. 1984); Leavell v.
Commissioner, 104 T.C. 140 (1995). A two-prong test has been set
forth by this Court in order for the wholly owned or closely held
corporation, rather than the service-performer employee, to be
considered responsible for the income. First, the service-
performer employee must be an employee of the corporation whom
the corporation has the right to direct or control in some
meaningful sense; and, second, there must exist between the
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